EFTA00157323.pdf
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Extracted Text (OCR)
From:
CUCANYS1 ICombeice:
To:
Subject:
RE: Epstein search warrant documents
Date:
Monday, July 13, 2020 9:08:17 M4
Attachments:
Waggpaigea
O
From: M,
I. (NY) (FBI) •,:
>
Sent: Monday, July 13, 2020 9:01 AM
To: M,
(USANY'S) [Contractor]
Subject: RE: Epstein search warrant documents
Sure. Give me a call at my desk.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From: 1=1,
USANYS) [Contractor] a
Sent: Monday, July 13, 2020 8:59 AM
To:
I. (NY) (FBI) <
>
Subject: RE: Epstein search warrant documents
Hello
I just got the hard drive and I have some questions about what is on the hard drive. Do you have a moment to
talk?
Thank you.
a
From:
I. (NY) (FBI)
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Sent: Wednesday, July 8, 2020 12:42 PM
To: IM
(USANYS) (Contractor)
Subject: RE Epstein search warrant documents
Thanks
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jul 8, 2020 12:41 PM,
(USANYS) [Contractor]"
wrote:
As soon as I have the hard drive I will reach out to you.
Thanks.
From: M.
I. (NY) (FBI) <
>
Sent: Wednesday, July 8, 2020 12:38 PM
To:
(USANYS) (Contractor)
Subject: RE: Epstein search warrant documents
Thats what I hear,they are going to get it to you.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jul 8, 2020 12:33 PM,
(USANYS) [Contractor]"
wrote:
I am assuming you are sending the data to One Saint Andrews correct?
From: IM
I. (NY) (FBI) •,:
M>
Sent: Wednesday, July 8, 2020 12:31 PM
To: IM
(USANYS) (Contractor)
Subject: RE Epstein search warrant documents
The drive will begin its joumey 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.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
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On Jul
'
(USANYS) [Contractor]"
wrote:
Hello
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.
From: MI
I. (NY) (181)
Sent: Tuesday, July 7, 2020 5:14 PM
To:
(USANYS) c
:*;
(USANYS) (Contractor)
Cc:
(USANYS) `'
IMIM
>;M•
(NY) (FBI) <
>;
(USANYS) <->;
(USANYS)
>;
(NY) (FBI)*MS
(USANYS) <
>
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.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From: a
(USANYS)
Sent: Tuesday, July 07, 2020 3:42 PM
To: My
I. (NY) (FBI) <;S
(USANYS) (Contractor)
Cc:
(USANYS) <M
>; M
I (NY) (FBI) <a
M
=
(USANYS)
In
UM
(USANYS) •
.
MI
(NY) (FBI) c:M
l>, M.
(USANYS) a>
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:
I. How many total devices are coming to us in this initial production?
I. What are those devices— i.e., type of device and which ones, from the spreadsheets you've
sent?
2. What's the total volume of data corning 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,
From:
(USANYS)
Sent: Tuesday, June 30, 2020 16:23
To: M,
I. (NY) (FBI)' la;
M,
c
>
Cc:
(USANYS)
I (NY) (FBI) a*,
(USANYS) cle•
(USANYS)
M.
(NY) (FBI)
(USANYS) <M
>
Subject: RE: Epstein search warrant documents
(USANYS) [Contractor]
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
(USANYS)
Sent: Monday, June 29, 2020 13:00
To:
I. (NY) (FBI) ce;
(USANYS) [Contractor]
Cc:
(USANYS) <
>;MI•
(NY) (FBI) <
:.;
(USANYS) <
>;
(USANYS) <>;
I. (NY) (FBI)
(USANYS).
>
Subject: RE: Epstein search warrant documents
Okay thanks
Thanks again.
And if you can let us know tomorrow that would be great.
From:
I. (NY) (FBI) <
>
Sent: Monday. June 29, 2020 12:59
To:
(USANYS) (Contractor)
(USANYS)
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Cc: NM
(USANYS) a>,
=(USANYS)<
>;
1• (NY) (FBI)
Subject: RE: Epstein search warrant documents
(USANYS)
(USANYS)
When I'm in the office tomorrow, I will be better able to estimate.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
I (NY) (FBI) <
On Jun 29, 2020 12:56 PM, "la
(USANYS)"
wrote:
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?
From: M.
I. (NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) (Contractor) a>:
(USANYS)
Cc:
(USANYS)
;M,
I. (NY) (FBI) <
:,)
(USANYS)
>;
(USANYS)
>;
MI
(NY) (FBI) c
'*;
(USANYS) al>
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM, "==,
(USANYS)"
wrote:
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?
From:
I. (NY) (FBI) c:n
Sent: Monday, June 29, 2020 12:50
To: IM
(USANYS) [Contractor] <a;
4:
)*
Cc:
(USANYS)
;
(USANYS)
;
MI.
(NY) (FBI) `S';
Subject: RE: Epstein search warrant documents
(USANYS)
I. (NY) (FBI) <
>;
(USANYS)
(USANYS)
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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.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM, "==,
(USANYS)"
wrote:
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,
From:
I. (NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To: M,
(USANYS) (Contractor) •f
>;
(USANYS)
Cc:
(USANYS)
>:
I (NY) (FBI) <
>;
(USANYS)
>;
(USANYS)
;
MI
(NY) (FBI)
*;
(USANYS) •c
>
Subject: RE: Epstein search warrant documents
I am in the process of expor igjhe 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.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM, '
wrote:
(USANYS)"
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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evrrythinv that was collected (including reproducing the materials that you previously gave us, but which are
not searchable), or have you and MI 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.
thanks,
From:
I. (NY) (FBI) a>
Sent: Friday, June 19, 2020 13:14
To: M.
(USANYS) (Contractor) cla;
4:
M>
(USANYS)
Cc:
(USANYS)
;
(NY) (FBI) <
>;
(USANYS) <->:
(USANYS)
MI
(NY) (FBI)
(USANYS) <
>
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.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
(USANYS)" <
wrote:
From:
(USANYS)
Sent: Wednesday, June 17, 2020 14:28
To:
I. (NY) (FBI) <a:1M
c
>
Cc:
I. (NY) (FBI) <Me=
(USANYS)
(USANYS)
1 (NY) (FBI) cMES;
(USANYS)
(USANYS) ca=>
Subject: RE: Epstein search warrant documents
(USANYS) [Contractor]
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•
From:
(NY) (FBI) *c
:'
Sent: Monday, June 01, 2020 16:28
To: M,
(USANYS) (Contractor) <a;
(USANYS)
Cc:
(NY) (FBI) c
. :*;
(USANYS)
';
(USANYS)
;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
(USANYS)"
wrote:
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.
From: M,
I. (NY) (FBI) a>
Sent: Monday, June 01. 2020 16:23
To:
(USANYS) (Contractor) <
>:
(USANYS)
Cc:
I (NY) (FBI) <->;
(USANYS)
>:
(USANYS) cat
(NY) (FBI) *
:*
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. Sony 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 many it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
wrote:
(USANYS)"
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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,
From: M.
I. (NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
(USANYS) <
Cc: M.
(USANYS) a
M.
Mg
(NY) (FBI) "c
';
Subject: Re: Epstein search warrant documents
>;_•
(USANYS) <
I. (NY) (FBI)
(USANYS) (Contractor)
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.
FBI NY CART Coordinator
Senior Examiner
From:
(USANYS) <
Sent: Friday, May 15, 2020 4:11 PM
To: M,
I. (NY) (FBI) `:
*;
(USANYS) [Contractor]
4:
)*
Cc:
(USANYS)
(USANYS)
(NY) (FBI) 'c
'*;
(FBI) `M
I >
Subject: RE: Epstein search warrant documents
I. (NY)
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I I I
I I I
From:
Sent: Thursday, May 14, 202015:50
To:
Cc:
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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FBI W CART Coordinator
Senior Examiner
From:
(USANYS)
Sent: Wednesday, May 13, 2020 12:25 PM
To: M,
I. (NY) (FBI) a
(USANYS) [Contractor]
Cc:
(USANYS)
;IM
(USANYS)
MI.
(NY) (FBI) `:
>;
(FBI) a>
Subject: RE: Epstein search warrant documents
I. (NY)
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 dots 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.
thanks,
From: 1=1,
1 (NY) (FBI) a>
Sent: Tuesday, May 12, 202013:03
To:
(USANYS) <
Cc: MI
(USANYS) `Ma
>. NM
(NY) (FBI) <
Subject: Re: Epstein search warrant documents
>;M.
(USANYS) (Contractor)
(USANYS)
;
I. (NY) (FBI) <
>
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.
FBI NY CART Coordinator
Senior Examiner
From:
(USANYS)
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (F80
(USANYS) [Contractor]
Cc:
(USANYS)
(USANYS)
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.
From:
I. (NY) (FBI) <
>
Sent: Tuesday, May 12, 2020 11:30
To: M,
(USANYS) (Contractor] <a;
(USANYS)
Cc: M, M(USANYS)<
';
(USANYS) <
Subject: RE: Epstein search warrant documents
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 MI since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Ma 12 2020 11:15 AM,'
(USANYS)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
I (NY) (FBI) <
>
Sent: Tuesday, May 12, 202011:11
To: M,
(USANYS) (Contractor) •cl
>;
(USANYS)
Cc:
(USANYS) <a;
MI
(USANYS) <
>
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem. MI and I ironed out all the details. We've got a good plan
moving forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM, "
(USANYS)"
wrote:
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,
From: M,
(USANYS) (Contractor) •c
>
Sent: Tuesday, May 12, 2020 10:27
To: a
(USANYS)
Cc: M
,
III. (NY) (FBI) la
Subject: RE: Epstein search warrant documents
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Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of
the data and where the data was collected. I will work to send some hard drives to
so he can begin to
copy the data and send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
(USANYS)<
>
Sent: Friday, May 8, 2020 2:15 PM
To: M,
I (NY) (FBI)
(USANYS).e,
(NY) (F8t)
(USANYS)
Cc:
(USANYS) (Contractor)
(USANYS)
(USANYS)
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Okay thanks — please do let us know if at any point that changes, otherwise we'll look forward to being able to
review the returns in early June. Thanks again.
From: M.
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(LISANYS)
;
(USANYS)
.
1- (NY) (FBI)
Cc: M.
(USANYS) (Contractor)
M,M
(USANYS)
4:
*;
(USANYS)
. (NY) (FBI)
Subject: RE: Epstein search warrant documents
(USANYS)
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially
gave you. If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM, 11
,
(USANYS)"
wrote:
Understood, thanks—it will be great to get that list on Thursday. As a refresh, the info we are looking for is in
the attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for
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complete transmission of the search warrant returns is no longer likely? If so could you please let us know
what the current estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI) *c
>
Sent: Friday, May OS, 2020 13:50
To:
(USANYS)
>;
(USAWS)
(NY) (FBI) a:
Cc: M.
MANN (Contractor) .:
*;
(USAWS)
`a;
;M
-(USANYS)
<Ma>:
(NY) (FBI) a>
Subject: RE: Epstein search warrant documents
(USANYS)
Sorry for the delay, they reduced us to I day a week, so things have been stretched out by a factor of 5.
I will be back in the office on Thursday and will be able to get you the list then as I have to access some
of our systems to do so.
Also, =,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
wrote:
(USANYS)"
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized
from the search warrants at Epstein's residences in New York and the USVI, as well as from his person upon
arrest, in about a month (during our conference call a month ago) — so wanted to check if we can still expect
that very soon? We're waiting on that list to be able to do an updated search warrant on all of those devices.
Please let us know the current timeline —and also the current timeline on producing the results from those
August and September searches? I think you and= were going to coordinate on that, and you had
mentioned you expected we'd have it a couple months from our call, which would be about a month from
now. Wanted to make sure we're still on track.
thanks,
From:
I (NY) (FBI)"
Sent: Tuesday, April 07, 2020 15:27
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(USANYS)
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. (NY) (FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know
until tomorrow am. I will push it out when confirmed.
Thanks
From:
(USANYS)
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
(USANYS)
I (NY) (FBI) a
IM
(USANYS)
Cc: M.
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(USANYS)
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Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on
your end.
Also, we can host a conference call, but only up to six lines at a time — so if FBI has larger capacity than that let
us know, otherwise I'd propose we do:
1)
2)
3) MI
4)
5)
6)
/In if either of you wants to join (and if not, one of 1=1/1
)
From: IS
(NY) (FBI) cr
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Sent: Tuesday, April 07, 2020 14:13
To:
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Subject: RE Epstein search warrant documents
l
eyou available tomorrow for a conference call to discuss this issue?
SSA
FBI New Vol*
On Apr 7, 2020 1:55 PM, '
(USANYS)"
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wrote:
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 were looking for is the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
(USANYS)
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
(USANYS)
(NY) (FBI) <
>;
(USANYS) <
>
Cc: M.
(USANYS) [Contractor] <
>; M,M
(USANYS)
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>;
(USANYS)
(NY) (FBI) <
>
Subject: RE; Epstein search warrant documents
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 search warrant
returns (that we sent on 2/23), and we don't have the 16 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.
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.
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
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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,
From:
I. (NY) (FBI) <
>
Sent: Wednesday, March 04, 2020 16:36
To:
(USANYS)
(USANYS)
(NY) (FBI) 'c
›;
(USANYS)
(USANYS) (Contractor) <
>;
(USANYS)
(USANYS)
Ma•
(NY) (FBI) `>
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load tiles 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.
NYO CART Coordinator
Senior Forensic Examiner
office)
(cell)
From:
(USANYS)
Sent: Tuesday, March 03, 202012:25 PM
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. (NY) (FBI) <I
IM)
Subject: RE: Epstein search warrant documents
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?
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From: M,
I. (NY) (FBI) <
>
Sent: Tuesday. March 03, 2020 09:59
To:
(USANYS)
;
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(NY) (FBI)
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=>
Cc: M.
(USANYS) (Contractor) cMe
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(USANYS)
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Subject: RE: Epstein search warrant documents
(USANYS)
Can we do Thursday morning? My network should be back by then and I can give you a good
accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM, "==,
(USANYS)" <
wrote:
Doing the weekly check in on this — is there a time this week when everyone can meet on this?
thanks,
From: 'Me
(USANYS)
Sent: Monday, February 24, 2020 17:38
To:
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Subject: RE: Epstein search warrant documents
Totally understand about the network issues—we can relate. I do still think it will be helpful to all sit down
together to have an in-person discussion, to make sure everybody is on the same page. Are folks available for
that next week? And what I think would be most helpful to facilitate that would be a spreadsheet of each
separate device referenced in the two search warrant returns, with columns for whether we've dumped the
contents, whether they've been reviewed and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful — and the info on
the attached is mostly hypothetical, obviously, just as examples. That will help us fully understand what's
been reviewed, transferred, and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices
— I think FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, well
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need to get those to be able to review them as well.)
many thanks,
From: M,
(NY) (FBI)
Sent: Monday. February 24, 202009:24
To:
(USANYS)
(USANYS)
(NY) (FBI)
Cc: l=
(USANYS) (Contractor) .:
>; =,M
(USANYS)
(USANYS)
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. (NY) (FBI)
Subject: RE Epstein search warrant documents
(USANYS)
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they
mandated we delete old stuff (about 400 TB worth). Now that they are working on replacing the
network, we can do only local work. I should be able to give you an accounting of what is what. I can
say, off the top of my head, that all windows based items from the NY search have been handed over as
well as all loose media. The CDs from NY only contained pictures, no documents. There are still some
Apple items from NY that need to be produced. As far as the Island stuff goes, the 1st item on your
spreadsheet, the "kitchen" mac has been produced. Still working on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM, "
(USANYS)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it
would make sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We
didn't hear back on which files had previously been provided, but our tech folks did their best to differentiate,
and we got access to the materials yesterday and its well over a million documents, and we don't have any
idea what we're looking at — i.e., which devices the materials came from, whether it's full or partial results,
how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not
even counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than
25 devices, including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot
of moving pieces on all sides so wanted to loop in everybody at once. The case team will be in California this
coming week from Tuesday through Friday, but then I think generally around the first week of March, which
will hopefully be plenty of time to schedule a productive meeting.
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thanks all,
From:
(USANYS)
Sent: Saturday, February 15, 2020 16:30
To:M„
(NT) (FBI)
Cc: M.
(USANYS) [Contractor] <:.
>;
M.M
(USANYS)
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>
Subject: RE: Epstein search warrant documents
=,S
(NY) (FBI) <
=>
(USANYS)
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it —
I have the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like
there are also old materials (that I think we had previously received and uploaded??) on the hard drive, and so
I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track
of what we're getting, and what has been completed, without some kind of identification or labeling system,
along with a list of which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with
a modified date of 11/14/19, which I think we may have already previously received — but I'm not sure,
because we haven't gotten any info on which folders match up to which devices, etc. And then there's
another folder titled "NYCO24362" that has a modified date of 1/27/20, so I think that may be the materials
we hadn't previously received? That folder by itself has more than 600,000 items.
I don't want to give [MI anything that we've already previously received and uploaded, and I can't tell from
the folder or file names whether everything on the drive is new, or whether just additional materials were
saved onto it in addition to what we already have. I=
are you able to give us some guidance on this?
Ultimately what we really need is a spreadsheet of every device, whether it's been dumped (or partially
dumped), and then identifying that same info —which device, and what materials from it —are being given to
us with each data transfer. Otherwise I think organizationally and for review purposes it will be a total disaster
for us.
We're happy to have a meeting on this if that's helpful — and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
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