EFTA00089653



Thanks, . Taking these one by one:

- We designated certain email accounts responsive, per our discussion, at that yielded 90,000 emails. The balance of the 1.4 million emails/documents comes from search terms.

- The database contains all kinds of documents—word, PDF, and excel. I haven’t seen any texts, and it’s mainly the kinds of things you’d expect to be saved on someone’s computer.

- I don’t have numbers by search term, but will check on that and circle back. We sent a list of terms to and asked him to execute, so I’m not sure about the breakdown.

- Yes, Maxwell is a search term and her email account has been designated responsive.



Thanks, . Couple of follow up questions on this, and happy to set up a call if that's easier.

First, am I understanding correctly that we ran all of our search terms and came up with 90,000 responsive emails and 1.31 million other responsive documents? Or is the 90,000 figure just email account?

Second, and related, with respect to the non-email documents, whatever their volume, do you have a sense of what kinds of documents we’re talking about? Word documents, texts, excel spreadsheets, some combination thereof?

Third, do you know how many documents hit on each term? If we came up with 1 million hits on the names of the victims, that’s one thing, but if we came up with a million hits on the word “flight” or “passenger” we might want to think about whether to narrow the terms a bit.

Also, I presume we ran Maxwell’s name as one of the co-conspirators and ran any email account of hers we identified as one of the email accounts?

As noted, happy to jump on a call tomorrow if that's easier.

Thanks,



We’ve run our responsiveness search terms for the search warrant returns, and they yield a total of 1.4 million documents. As a breakdown, 90,000 of those items are emails we designated responsive by account (for example, ). The remaining documents are hits on our search terms, which included the first and last names of every victim and suspected co-conspirators, as well as specific keywords (e.g., passenger, flight). The total database is 1.6 million documents.

EFTA00089654

1. 4 million documents is obviously a substantial portion of the 1.6 million document database. Given our prior discussions, our understanding is that the office is okay with us designating all of these documents responsive, but please let us know if you’d like us to take a different approach.

Thanks,

Assistant United States Attorney

Southern District of New York

One Saint Andrew’s Plaza

New York, NY 10007

EFTA00089655