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Subject: RE: Status update: Maxwell discovery issue files review¶
Hi¶
Attached is the spreadsheet with each problem file that Maxwell’s counsel listed and our corresponding notes. This does not include the “Images Not Exported” section as we are having re-export those for us to double check. There is one group of files that we’d like to bring to your attention:¶
In the “Corrupt” tab of the spreadsheet you’ll see that there are a number of files which are labeled “Lazer Scan.” These are the same files that we dealt with last August/September (linked here), which I believe we worked out to be 3D renderings and scans of Epstein’s compound. and I both recall dealing with this extensively but are having trouble locating emails documenting that fact other than the attached. Happy to discuss over the phone if you’d like and determine a better way to mark them in the spreadsheet.¶
Besides that, the list of files should be good to go. And we can inform counsel tonight that we are already working with the vendor to address any files we found to have any issues.¶
Please let us know if you have any questions or comments on the spreadsheet.¶
Thanks,¶
Subject: RE: Status update: Maxwell discovery issue files review¶
Great, thanks. I’ll send an invite for 1:30.¶
Subject: RE: Status update: Maxwell discovery issue files review¶
Of course. , and I are all available from 1pm on.¶
Subject: RE: Status update: Maxwell discovery issue files review¶
H¶
EFTA00089752¶
Can we have a call to touch base on this today, please?¶
Subject: Status update: Maxwell discovery issue files review¶
Hi all,¶
Here is our status update for the review of discovery files that Maxwell is having various issues with, categorized by issue and whether the file was from a PAE export or something we stamped on the shared.¶
- Blank files
From PAE export (29 pages/files): all but one of these files that were described as “blank” were in fact blank files; nothing more to do for these files. The one non-blank file among these (SDNY_GM_00218894) has no native file that was produced with it (we will look into/confirm with PAE re: whether this was intentional or an oversight), but the image produced for this Bates number should not appear “blank.”¶
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From shared drive/stamped by SDNY (308 pages/files): none of these pages were blank. They all were pages within Deutsche Bank records from Production 2.
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Corrupt files
o From PAE export (501 pages/files): the initial review of these files is complete, and 290 documents were corrupt in their native produced form when we opened them. There are additionally about 160 documents of varying file types that we did not identify as corrupt but had various issues opening or viewing, which could possibly explain why she had an issue with them. We (paras) can confer more about these files early next week and let you know what we think we should do next (e.g., ask PAE to re-export them, determine whether we/she has appropriate software for viewing, etc.). The remaining pages/files among the 501 identified for review in this category are duplicates of other Bates identified as “corrupt.”¶
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From shared drive/stamped by SDNY (2152 pages/files): none of the pdf files identified by defense as “corrupt” were corrupt per our review; all files were able to be opened, and all Bates numbered pages were able to be viewed.
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However, there is a range of files (SDNY_GM_00169505-SDNY_GM_00169737 from Production 3 (SDNY_GM_00166191-SDNY_GM_00169759 (Search warrant photos))) that defense listed as “corrupt” but they seem to be weird computer/electronic system files. I cannot open these files to see what they are (many seem to be .fls files or other systems-related unknown file types), and I’m not sure if you previously identified what these files are in particular, either internally when initially producing them or to defense counsel. These files can be found here for our reference/review, and we (paras) will again touch base about these next week to determine to what extent we can help her view them (or whether they are even viewable to us).
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Missing
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From PAE export: pending review of master copy discovery hard drive
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From shared drive/stamped by SDNY: neither file is missing/no issues with these files
Can’t read/won’t open¶
- From PAE export: pending review of master copy discovery hard drive
o From shared drive/stamped by SDNY: no issue with these files¶
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Not supported
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From PAE export: pending review of master copy discovery hard drive
No files with this issue from shared drive/stamped by SDNY¶
- Images not exported
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• From PAE export: pending review of saved searches from¶
From shared drive/stamped by SDNY: no issues with these files
¶
All in all, the files identified as “blank” and “corrupt” are nearly done being reviewed, and we’ll aim to get as much done as we can on the remaining categories in the next week. Let us know if you have questions based on this initial review, and we’ll keep you posted as we made additional progress.¶
Thanks,¶
Paralegal Specialist¶
U. S. Attorney’s Office | SDNY¶
1 Saint Andrew’s Plaza¶
New York, NY 10007¶
Office:¶
Cell:¶
EFTA00089754¶