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Following up on this from a month ago – I know we’re living in a different world than what existed four weeks ago, but are you at all able to assist while working remotely? This has been pending for almost two months and we still don’t have a very basic list of each device or item that was seized and searched, or for which of those we’ve received materials. We’re happy to have a call if that would be useful, but as a first step the most basic thing we’re looking for is the info in the template spreadsheet we sent earlier (that’s also attached).¶
thanks,¶
Unfortunately I don’t think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The excel file you sent has descriptions that don’t match up to the items listed in the¶
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search warrant returns (that we sent on 2/23), and we don’t have the 1B or CART numbers to be able to cross-reference. We also can’t tell what you mean by “loose media” without a specific comparison to what was seized, we don’t know which items you’re referring to as “Windows machines,” and we can’t tell whether the entirety of any particular item has been transferred, or just partial. For example, it looks like we have gotten very, very few image files, which is surprising.¶
We have also encountered some very significant problems in trying to review the more than 1 million documents we recently received:¶
The data we’ve received has no way to put any emails and attachments together. So if an email says, “see the attached flight records,” for example, we have no way of linking that up with the records themselves. Not only is that a big problem for us in review, it’s going to be a huge problem for producing the documents to defense counsel.¶
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The load file has no link to the native file, so when we load the data to the database, there’s no way to have the native files show up in the database. Because many of the files are too large to open in the viewer, it effectively means that there are many files that are completely invisible to us.
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Related, the control numbers in the load file don’t match up to the native files. So we have two sets of numbers and no way to match up anything—that is, even if we were to try to go hunt down every individual large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get a similar reproduction of the data we received a couple months ago.¶
Otherwise we’re sifting through more than a million documents without much rhyme or reason.¶
I’ve re-attached the spreadsheet we sent last week – I think that’s a good place to start in terms of our necessary record-keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW returns for reference. And again, we’re happy to meet up anytime and hash all this out in person if that’s useful.¶
thanks,¶
Subject: RE: Epstein search warrant documents¶
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Here is a listing of what I have already handed over in load files to the US Attorney’s Office for taint review. Some points of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2 Macs from NY and 1 from the Island are included.¶
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool they have to be processed with does not easily re-name the load files.¶
Spreadsheet is attached.¶
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we can figure out in advance what (if any) additional steps we need – is that possible?¶
Subject: RE: Epstein search warrant documents¶
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.¶
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