Subject: RE: Discovery Issues¶
Date: Wed, 12 May 2021 13:36:03 +0000¶
Inline-Images: image001.jpg; image002.jpg¶
and I are both available anytime today.¶
Subject: FW: Discovery Issues¶
Hi team,¶
Maxwell’s attorneys have asked for the below-listed information from the SUPP production that went out on November 9, 2021. Is there a time tomorrow when we can have a call to discuss, please?¶
Thanks,¶
Also following up on your response to Chris. We have had a chance to take a look at these files again.¶
For the SUPP production, many of the files were produced as PDFs, which seems as though they were converted prior to production. As I understand it (which is admittedly limited), carved or deleted files can still contain application metadata.¶
We request that as to the SUPP production, you:¶
a. Provide a list of all files that were carved or deleted;¶
b. Confirm if all those files were produced in native format or if any were converted to PDF;¶
c. If any were converted, provide additional information including the MIME type (for all), and if available from application metadata original file name, file dates, etc. This would amount to the equivalent of the index you provided for SDNY011.¶
d. In the absence of (b), confirm that no application metadata was recovered from those files which might indicate file creation/modified dates¶
EFTA00096503¶
Please let me know if you have any questions.¶
Chris,¶
Following up on these issues:¶
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For #3, the attachments were not recovered from the searched devices. We do not have them, which is why they were not produced.
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For #4, the electronic files recovered from Epstein’s devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data showing when a particular file was saved to a drive by the investigative team or prepared for production. I am not aware of any additional metadata in our possession that you do not have for these files.
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For #5, those photographs were not processed by CART, which is why they do not have a CART number. They came from the CDs that your team reviewed last week. The available metadata for those photographs was produced in two excel spreadsheets with the same production – one with metadata for nude images (which were contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet.
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For #6:
o The SDNY_GM_SUPP contain electronic files recovered from Epstein’s devices. As noted above, those files have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable.¶
o The videos from SDNY005 (October 20, 2020 production) were converted by a vendor from VHS and cassette tapes, so there is no metadata to provide. The Sept-Octo 2020 dates reflect when these recordings were converted by our vendor.¶
- The SDNY011 (November 9, 2020 production) consists of images from the CDs seized from Epstein’s residences, which you reviewed last week. As referenced above, those photographs were not processed by CART, which is why they do not have a CART number. As referenced above, the available metadata for those photographs was produced in two excel spreadsheets with the same production – one with metadata for nude images (which were contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet.
EFTA00096504¶
Apologies for the late response on this. It seems like it would be better to confer after you have heard back from your vendor, since the answers to #3-#6 will depend on what the vendor says. And I believe we have now resolved #7.¶