EFTA00081436¶
Subject: Epstein priv review — 1B83 released¶
We just finished 1B83. 30 emails were removed as potentially privileged. The redacted report is saved to your shared directory below but DO NOT open it from the shared or it will shut down the office network. Save it to your D drive or can put it on a flashdrive.¶
The first two phones are up on the Priv share. (71 and 72).¶
Subject: RE: Help with Epstein Privilege Review¶
Thank you!¶
Subject: RE: Help with Epstein Privilege Review¶
Yes. And I will produce on a rolling basis to¶
EFTA00081437¶
Subject: RE: Help with Epstein Privilege Review¶
Great, can you do 1B72 first and if we still don’t have a PRIV shared directory, email it to just me? The case team is on a tight discovery deadline so I want to get reviewing asap.¶
Subject: RE: Help with Epstein Privilege Review¶
Got it. This will take me a few hours to complete. I’ll let you know when it’s done.¶
Subject: RE: Help with Epstein Privilege Review¶
Great! Can you create the following extractions from the Epstein HD? And save them to the Priv shared directory as soon as I can create one? And then I’ll have start reviewing them for privilege.¶
| 1B71 – Chats and SMS |¶
| :--- | :---¶
1B72 – Chats¶
1B69 - Chats¶
1B84 – Chats¶
1B83 - Chats¶
Subject: Re: Help with Epstein Privilege Review¶
Yes I’m in. Let me know what you need.¶
EFTA00081438¶
| Enrique Santos |¶
|-----------------|¶
| Investigative Analyst |¶
| U.S. Attorney’s Office, SDNY |¶
Can you help me today on this?¶
Subject: RE: Help with Epstein Privilege Review¶
Do you guys have a shared directory? Can you send me the link? I need to set up a Privilege shared directory.¶
or Enrique will correct me if they have a better way but I think the best way to generate the Responsive Report is to deselect (by removing the x in the column on the far left) all the data in the report and then go to the Tags view and select (by putting the x back in the column on the far left) all your tags. You then go up to the top left and choose the Report drop down and then choose Generate a New Report. Be sure to name it something that makes it clear that it is the Responsive report and you can also choose whether to create a UFDR report or a PDF.¶
I’ll give you an update on the other reports shortly.¶
Subject: RE: Help with Epstein Privilege Review¶
EFTA00081439¶
I’ve finished the responsiveness review of the four reports that generated last week. I’ve tagged all of the responsive items in each report. What should my next step be to generate reports that only include the tagged items?¶
Now that these are done and I are all just waiting on the release of the remaining portions of 1B72 and 1B69, as well as any content from 1B71, 1B83, and 1B84. As soon as you can release even just some of those reports, we will dive into the responsiveness review.¶
To give you a sense of timing: In order to give our paralegals enough time to prepare the responsive materials for production in time for our 11/9 deadline, we need to finish the responsiveness review by no later than Thursday 11/5. So the sooner we can get anything over the wall for us to review, the better.¶
Thanks very much,¶
Just to be safe, please double check when you open up the reports that they correspond to the notes below, i.e., 1B72 should not have chats and 1B69 should not have chats and should only have 1074 emails. And as always please stop your review and let me know if you come across anything else that you think may be privileged. Thanks!¶
1B72 – Release without chats¶
1B67 – Release entire report¶
1B68 – Release entire report¶
1B69 – Release without chats and without the 93 PP emails, as tagged on the attached .pas file (so only release 1074 emails)¶
Subject: RE: Help with Epstein Privilege Review¶
You can stop by now if you’d like. I have the drive.¶