EFTA00089744¶
(bcsternheim@mac.com)’ bcsternheim@mac.com Subject: FW: US v. Maxwell - [conferral re photo and other discovery deficiencies]¶
Thank you for sending the overlay. After review, it unfortunately does not appear sufficient to allow us to properly match the metadata to your production of native files.¶
Based on your representations, the “Non-Nude index” located at Bates 467567 in Excel should match the Bates number native images produced at SDNY011. However:¶
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The number of entries in the Non-Nude Index is less than the number of files produced.
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Although the overlay file has 40,567 entries (the same number of files in SDNY011), they don’t match up to the Non-Nude Index.
- When joining the overlay file to the index:
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If we require a matching value for both MD5 hash and file name, there are 24,757 entries in the overlay that do not match the index.
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If we require a match on the hash value and ignore file names, there are 65 production numbers that don’t match the index; 17 of those don’t have hash values at all.
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The overlay has many non-unique hash values, meaning we cannot rely on hash value alone.
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The Non-Nude index also has many non-unique hash values.
I think the only feasible resolution is for you to provide a new copy of the non-nude index with an added column to note the production number of each file. We also need a new index for the produced files that were not included in the prior index.¶
Let me know if you will agree to produce these two new indices.¶
Laura,¶
Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein’s residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY_GM_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production.¶
Best,¶
Assistant United States Attorney¶
Southern District of New York¶
1 St. Plaza¶
New York, NY 10007¶