EFTA00038175.pdf

From: [Redacted]
To: [Redacted]
Cc: [Redacted]
Subject: RE: [EXTERNAL EMAIL] - RE: outstanding discovery issues
Date: Fri, 23 Oct 2020 22:31:59 +0000
Importance: Normal

Great, thank you!

From: [Redacted]
Sent: Friday, October 23, 2020 6:26 PM
To: [Redacted]
Cc: [Redacted]
Subject: [EXTERNAL EMAIL] - RE: outstanding discovery issues

We will separate them out and keep them with the others.

-

On Oct 23, 2020 5:49 PM, "[Redacted]" wrote:
Hi [Redacted],

Wanted to make sure this didn’t slip through the cracks. Where are you planning to keep the scans of images from the Florida boxes? Ideally, we would like them maintained together with the other nude images so that if/when defense counsel comes to review nude images at the FBI, they will all be in one place.

Thanks,
[Redacted]

From: [Redacted]
Sent: Thursday, October 22, 2020 8:25 PM
To: [Redacted]
Cc: [Redacted]
Subject: RE: outstanding discovery issues

Thanks very much, [Redacted].

What is the plan for the black and white scans of images from the Florida boxes?

From: [Redacted]
Sent: Thursday, October 22, 2020 8:17 PM
To: [Redacted]
Cc: [Redacted]
Subject: RE: outstanding discovery issues

See below.

EFTA00038175

From: [Redacted]
Sent: Thursday, October 22, 2020 12:16 PM
To: [Redacted]
Cc: [Redacted]
Subject: [EXTERNAL EMAIL] - outstanding discovery issues

[Redacted] and [Redacted],

Following up on my conversation with [Redacted] this morning about several discovery items that are outstanding, I wanted to send a list of the outstanding items for discovery. I know you’re aware of these and working on them, but I wanted to make it easier for us all to keep track of what’s outstanding. If you could please send us an email at the end of today letting us know where we are on these, it would be extremely helpful:

1. Locating six images of child pornography in the Florida boxes. Located. They’re black and white scans of images.
2. Putting us in touch with [Redacted] contact at FBI who can help us discuss converting the grand jury audio to a readable format. Another agent will be looking at this tomorrow
3. Putting us in touch with [Redacted] contact at FBI who can help us discuss getting a version of the GPS/1D data from Maxwell’s phone in a readable format. The data we have is unreadable. I figured out the problem. You received the raw data which is why it is unreadable. My apologies. I’ll have the viewable data tomorrow for you. It is the IP data from the pen.
4. Putting us in touch with the agents who are conducting the responsiveness review of the images, so that we can have a brief call with them to discuss the protocol.
5. Doing a final sweep of media in the files, so we can make absolutely sure we’ve reviewed everything. I’m going through the boxes/files to find any additional media.

When we talk at 3 today, please let us know if you have any questions about these items, happy to discuss.

Thanks,
[Redacted]

EFTA00038176