Subject: RE: Discovery review project¶
Date: Tue, 13 Oct 2020 20:33:41 +0000¶
Yes sure¶
Sent: Tuesday, October 13, 2020 4:33 PM¶
Subject: RE: Discovery review project¶
That works for me. Should we send to chiefs for their review?¶
Sent: Tuesday, October 13, 2020 4:31 PM¶
Subject: RE: Discovery review project¶
So the number we are producing is reflected through the bates range, I think. On the anonymized list, why don’t we just say a list of custodians is available if requested?¶
Sent: Tuesday, October 13, 2020 4:26 PM¶
Subject: RE: Discovery review project¶
This looks fine with two suggestions:¶
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Do we want to mention the number of items we are producing?
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Do we want to provide an anonymized list of the individuals whose email accounts we have?
Sent: Tuesday, October 13, 2020 3:56 PM¶
To: (USANYS) <¶
Subject: RE: Discovery review project¶
Here’s a revised letter with the discussion of the email searches in a footnote. Let me know what you think and then we can copy it over to the other one.¶
From: (USANYS) <¶
Sent: Tuesday, October 13, 2020 1:10 PM¶
Subject: FW: Discovery review project¶
Would you be able to review and add the language about the email searches?¶
Sent: Tuesday, October 13, 2020 1:08 PM¶
EFTA00101144¶
Subject: RE: Discovery review project¶
Redactions and stamping are all set. Everything is currently being zipped for upload to USAfx. I’ve drafted up cover letters to both Noel and Thomas. They are attached and saved on the shared.¶
Subject: RE: Discovery review project¶
Great!¶
Subject: RE: Discovery review project¶
Once I apply the reactions and stamp those documents, the production will be ready to go out. I will let you know once that is finished.¶
Subject: FW: Discovery review project¶
As per the attached, there are no additional redactions in the two outstanding FOIA email files. Let us know where the discovery stands.¶
Thanks,¶
I apologize for the delay, I’ve reviewed the two files please see attached V3 of the spreadsheet.¶
I am flagging 2 parts I was uncertain about, similar to earlier. (See below & in the spreadsheet)¶
On Emails 2_Part 4: I did note the same category as earlier with an email chain from Tartaglione’s counsel regarding leak/retaliation at MCC of a news story of Tartaglione questioned about attack on Epstein, and also on pg. 104 where Epstein informs a psychologist that Tartaglione discussed potentially injuring him without a guards’ report.¶
EFTA00101145¶
But both of those I was a bit uncertain whether they should be withheld.¶
Yes of course! I’m in class right now, but I should be able to work on this afternoon, and hopefully turn it back around by around 3pm if that’s okay?¶
There are replacements for the two corrupt files in the same shared directory you used before. Would you be able to take a look at those today and add them to this version of the spreadsheet (which has a few edits from what you sent)?¶
Okay, I finished up the remaining (pending the 2 pdfs I cannot open). I also noticed an error in the previous excel sheet, please utilize V2 moving forward (attached).¶
EFTA00101146¶
I grouped & highlighted 3 portions of different PDFs that, potentially could be withheld, as they’re email correspondence regarding Tartaglione but in relation to an Epstein incident. I tried to better define them in the spreadsheet and color coded by grouping. For the most part, each group is the same email chain, albeit with a response or two added.¶
Subject: RE: Discovery review project¶
Thanks for this. I will ask our paralegal to check out the damaged documents.¶
Following up with a quick update, I’ve got 6 PDF’s left to review. Wanted to flag that for some reason 2 of the PDF’s (Emails 2_Part4 & Emails 3_Part 2) will not open and I get a “document is damaged” error from Adobe. I’ve tried logging out of the portal and restarting computer but no luck so far.¶
I’m attaching the current spreadsheet so you can see how I’ve gone about flagging portions of the PDFs. I’ve noted a few uncertain areas in the notes where it may be Tartaglione issue but related to Epstein/request to be interviewed or for preservation.¶
Hope this is on the right track!¶
As we discussed, I would like you to review the email files only in the folder listed below. Please identify any pages in the documents that relate solely to (1) the conditions of confinement for Tartaglione or (2) emails with regarding Touhy. You should create a document (spreadsheet maybe) that identifies the name of the PDF file and the pages that fall in each category, so that the paralegals can redact those pages.¶
Here’s where you find the documents:¶
You only need to review the emails, not the other documents in the folder.¶
EFTA00101147¶
Let me know if you have any questions or issues once you start working on the project. Let’s aim for the end of the day on Wednesday.¶
Thanks for your help,¶
Assistant United States Attorney United States Attorney’s Office Southern District of New York¶
Tel: [black rectangle] Fax: [black rectangle]¶
EFTA00101148¶