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As soon as I have the hard drive I will reach out to you.¶
Thanks.¶
Thats what I hear,they are going to get it to you.¶
I am assuming you are sending the data to One Saint Andrews correct?¶
Sent: Wednesday, July 8, 2020 12:31 PM¶
Subject: RE: Epstein search warrant documents¶
The drive will begin its journey to you in minutes. Reach out when you get it to go over stuff so you aren’t looking at it like a dog looking at a tuba.¶
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Our office is not open and I am still working from home. Is it possible to have this data sent to my home?¶
Thank you.¶
Subject: RE: Epstein search warrant documents¶
Everything with the exception of a couple of items are ready. I will get you an actual number before I send it over. We can send it over tomorrow. There will be ReadMe files included so it will be easy to see where the items came from. I am a little worried about how the e-mail will present. While looking through on a spot check, the attachments are not connected to the e-mails in the forensic tool. I believe it is a function of the e-mail client they were using to begin with. I know that the attachments are a concern of yours. We may have to massage things a bit to get it right. Now that we are working every day, and everything has been processed, it shouldn’t be too big a deal. So far the export is about 350 GB. It copies slowly because it is a ton of pretty small files. You are getting the whole ball of wax, here, Macs, Windows boxes, loose media, etc. There will be a few iPhone and iPad reports, but unsure if I can get you those tomorrow as they very often take a LONG time to copy. Again, lots of small files. If not tomorrow, the next day.¶
Are you around tomorrow? Reach out to me when you get the production so we can correct any problems we might encounter. Thanks.¶
Subject: RE: Epstein search warrant documents¶
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I understand that some number of the devices are ready to come to us as early as today or tomorrow. Could you please let us know the following information, so we can figure out who the hard drive should go to in the first instance:¶
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How many total devices are coming to us in this initial production?
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What are those devices – i.e., type of device and which ones, from the spreadsheets you’ve sent?
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What’s the total volume of data coming in this round of production?
Once we know that, I can let the agents know where the drive needs to go in the first instance.¶
thanks,¶
Checking in for the estimate of when we can expect to get all the USVI materials?¶
thanks,¶
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Subject: RE: Epstein search warrant documents¶
When I’m in the office tomorrow, I will be better able to estimate.¶
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you’ll be able to see how many items to export, so we’ll have a better sense of when we’ll get those?¶
Subject: RE: Epstein search warrant documents¶
Yep¶
Okay, and I’m sorry to ask again, but to make sure, in this production, you’re sending us new versions of what you previously sent?¶
Subject: RE: Epstein search warrant documents¶
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You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS (there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how many items I have to export.¶
On Jun 29, 2020 12:40 PM,¶
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI materials? I think that is quite a bit more. Just looking for an estimated completion date for everything.¶
And on my other question – does this mean you’re giving us a new, complete copy of everything from both NY and USVI?¶
thanks,¶
Subject: RE: Epstein search warrant documents¶
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per my discussions with . Most of the NY stuff is done, just Mac items left. This might take a few days as 1 item in particular has over 500,000 emails. We will be able to provide discovery once Defense Council has provided drives for us to copy items over to. This goes quicker as there is no processing involved. I’ll let you know when everything is complete.¶
Following up on this, I understand from that she was able to provide you with a 12 TB drive last week – could you please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as early as this week.¶
Also, the related critical question that I don’t think we have clarity on is whether you’re giving us a copy of¶
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everything that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or have you and figured out a way to categorize the prior productions so they’re useful for us? We would strongly prefer to just get everything at once in a usable format, but please let us know if you expect to produce materials differently than that.¶
Subject: RE: Epstein search warrant documents¶
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can expect the drives. Thanks.¶
Subject: RE: Epstein search warrant documents¶
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Subject: RE: Epstein search warrant documents¶
Understood, and thanks for letting us know. Let’s keep in touch both on timing and also on whether there’s a way to identify and categorize what’s already been produced, or if we’ll need to just get all the raw data at this stage and go from there.¶
Subject: RE: Epstein search warrant documents¶
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we can’t make heads or tails of the stuff I’ve already produced, we’ll do it again. They have told us that our staffing levels will be steadily increasing over the next few weeks, but I’m going to have to push back my estimate by a week or 2. Sorry about that. My next day in the office is Thursday, so I’ll be able to see if I can easily identify what I already gave you and marry it to a reliable identifier.¶
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Thanks for this update – we’ll take a look and circle back if any questions.¶
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be transferred to us, and I think it’s right that the plan is to reproduce all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren’t able to match any of the prior productions to specific devices – so if we’re able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.¶
And related to that question, are we still on track to get the full range of data in the next week or so? I don’t think we’ve gotten any updates on that status in the past few weeks, and we’re eager to be able to start reviewing.¶
thanks again,¶
Subject: Re: Epstein search warrant documents¶
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number visible externally, but will report one through our tools. I included those electronically reported serial numbers. Any questions, let me know.¶
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| EFTA_00002151 | | :--- | :--- |¶
This is a simple Markdown document with no headings or paragraphs. It contains a single line of text.¶
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Sent: Thursday, May 14, 2020 15:54¶
Subject: Re: Epstein search warrant documents¶
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the unique numbers CART NY uses fro their evidence. The template wasn’t a slam dunk over, so I did what I could to convey the information. If you are confused by anything, please let me know. In the column for approximate size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don’t have as well as an iPhone and an iPad. IF the descriptions are a bit light, let me know and I’ll do what I can to beef them up. I will get you the Island stuff tomorrow.¶
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Respectfully, I think there are some miscommunications here – all we have asked is to receive the materials in a format such that we can view them using a system we have access to. We’re not able to get web-enabled access through any FBI tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both we and the agents can access. We’re required to have the files in a format that we can produce them to defense counsel. I’ve done that in many other cases and it hasn’t previously been an issue. My understanding from is that the best way to do it now is just for us (the U.S. Attorney’s Office) to get the original files, which our vendor will process—by which I just mean converting into file formats that are loadable onto Relativity. It doesn’t really have anything to do with the taint review—we have to have access to the docs in our systems for discovery purposes.¶
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier this year, they were in a format that wasn’t usable for the reasons described in the email I sent on March 9. Again, I understand from that the best way forward is to just get copies of the materials in their original formats, which I understand will be segregated and designated by device. That should work for us! I was just trying to understand the approach, as well as the timeline.¶
Just to be clear. The US Attorney’s Office (or it’s contractors) are not “processing” anything. You are taking files that I will be extracting from processed evidence and putting them into an E-Discovery tool¶
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(Relativity) to do a taint review.¶
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a computer like free space, slack space, and system files to name a few. When we started this, and you insisted you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now and I have come up with a way to fit this round peg into this square hole. We will get it done.¶
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece by piece as things are processed, I was unaware that you didn’t want to review as things were processed, that you wanted to do it “all at once”, so that added to the delay. Sorry for that. Just a differentiation of methodology I suppose.¶
and I feel confident that the method we have come up with will be more consistent and preserve the attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while back was lacking.¶
Subject: RE: Epstein search warrant documents¶
Okay, so just to check, you both think that there is not a need to do a test run? You’re both comfortable with just basically sending us copies of everything? I don’t totally understand why we couldn’t have done that eight months ago, but regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that means that we (at the U.S. Attorney’s Office and through contractors) will therefore need to do all the processing ourselves, correct? And thanks again to you both.¶
Like said in his earlier email. It will be the raw data and it will be marked so it is easier to¶
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attribute it to a particular device. Problem now is how to get the data to since he is teleworking.¶
I have no doubt you do, but can you please tell us what that plan is? Thanks!¶
Subject: RE: Epstein search warrant documents¶
I will use the spreadsheet, no problem. and I ironed out all the details. We’ve got a good plan moving forward that will meet your needs.¶
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately wasn’t helpful for us, so we want to make sure we’re all on the same page.¶
In terms of data transfer, are you just sending a literal copy of all the raw data, and we’ll process and upload it on our end? I ask to make sure we don’t lose any searchability – when FBI sent versions before, it had already been processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to make sure it transfers correctly, before sending over literally everything – is that still the plan?¶
thanks,¶
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