EFTA00027491.pdf

From: [Redacted] (USANYS) <[Redacted]>
To: [Redacted] (USANYS) <[Redacted]>
Bcc: [Redacted] (USANYS) <[Redacted]>
Subject: Re: Epstein search warrant documents
Date: Thu, 02 Jul 2020 23:15:54 +0000

I understand.

On Jul 2, 2020, at 7:13 PM, [Redacted] (USANYS) <[Redacted]> wrote:
Let's discuss. I just don't have a lot of confidence that [Redacted] is going to get this done.
Sent from my iPhone

On Jul 2, 2020, at 6:35 PM, [Redacted] (USANYS) <[Redacted]> wrote:
Ok. [Redacted] is also prepared to call [Redacted] about pushing this issue if need be.

On Jul 2, 2020, at 6:32 PM, [Redacted] (USANYS) <[Redacted]> wrote:
On this issue of the Epstein devices, the team got an estimate from BRG that seems reasonable in terms of both cost and time line. At this point, I would be inclined to do this, but let's find some time to chat more about it tomorrow if you're around or early next week if that's better. Thanks

From: [Redacted]
Sent: Thursday, July 2, 2020 5:11 PM
To: [Redacted] (USANYS)
Cc: [Redacted] (USANYS)
Subject: RE: Epstein search warrant documents

Following up on the below, I think we've given this our absolute best efforts with FBI – they are now well over a month later than their estimate from April on when we would get the New York materials, they're also past their estimate of getting us the New York materials from just this Monday, and we don't have anything close to an estimate on the USVI materials, which constitute the overwhelming majority of the data and are vastly more voluminous than the New York devices. We have kept pushing the timeline back for this option, hoping that CART will finalize, but I think at this point we should have a vendor do it.

Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-friendly format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very effective and efficient, and they get the materials we need. And most importantly, they estimate they can do it all in less than a month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.

[Page 2]
From: [Redacted]
Sent: Tuesday, June 30, 2020 16:23
To: [Redacted] (NY) (FBI); [Redacted] (USANYS) [Contractor]
Cc: [Redacted] (USANYS); [Redacted] (NY) (FBI)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
[Redacted]

From: [Redacted]
Sent: Monday, June 29, 2020 13:00
Subject: RE: Epstein search warrant documents
Okay thanks — good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks again.

From: [Redacted] (NY) (FBI)
Sent: Monday, June 29, 2020 12:59
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner

On Jun 29, 2020 12:56 PM, [Redacted] 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?

[Page 3]
From: [Redacted] (NY) (FBI)
Sent: Monday, June 29, 2020 12:55
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator

On Jun 29, 2020 12:52 PM, [Redacted] 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: [Redacted] (NY) (FBI)
Sent: Monday, June 29, 2020 12:50
Subject: RE: Epstein search warrant documents
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, [Redacted] 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?

[Page 4]
From: [Redacted] (NY) (FBI)
Sent: Monday, June 29, 2020 12:34
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 [Redacted]. 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.

On Jun 29, 2020 11:03 AM, [Redacted] wrote:
Following up on this, I understand from [Redacted] 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 everything that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or have you and [Redacted] 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.

From: [Redacted] (NY) (FBI)
Sent: Friday, June 19, 2020 13:14
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 [Redacted] 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

[Page 5]
On Jun 19, 2020 1:09 PM, [Redacted] wrote:
[Redacted], following up on the below – please let us know? Given case developments in recent days, this has become urgent. Thanks.

From: [Redacted]
Sent: Wednesday, June 17, 2020 14:28
Subject: RE: Epstein search warrant documents
[Redacted],
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and September searches before moving forward with possible additional charges in the case. I know you had mentioned you needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what the current estimate is?

From: [Redacted] (NY) (FBI)
Sent: Monday, June 01, 2020 16:28
Subject: RE: Epstein search warrant documents
Will do.

On Jun 1, 2020 4:26 PM, [Redacted] 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.

[Page 6]
From: [Redacted] (NY) (FBI)
Subject: RE: Epstein search warrant documents
[Redacted],
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.

On Jun 1, 2020 4:13 PM, [Redacted] wrote:
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... 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.

From: [Redacted] (NY) (FBI)
Sent: Friday, May 29, 2020 12:53
Subject: Re: Epstein search warrant documents
[Redacted],
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

[Page 7]
From: [Redacted]
Sent: Friday, May 15, 2020 4:11 PM
Subject: RE: Epstein search warrant documents
[Redacted],
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information we need is the serial number... we need to be able to somehow differentiate the following devices –
- The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
- The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
- the following loose storage devices:
o Micro SD card (NYC024339)
o Flash Drive (generic) (NYC024340)
o Thumbdrive (Emtec) (NYC024341)
o hard drive (loose) (NYC024342)
o verbatim thumbdrive (NYC024343)
- The four San Disk cruzer-thumbdrives (NYC024344-47)
- The three Seagate IDE hard drives (NYC024348-50)
- The camera SD card (NYC024351)

I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI list also has – is that info available?

From: [Redacted] (NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
Subject: Re: Epstein search warrant documents

[Page 8]
[Redacted],
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... 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.
FBI NY CART Coordinator

From: [Redacted]
Sent: Wednesday, May 13, 2020 12:25 PM
Subject: RE: Epstein search warrant documents
[Redacted],
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... My understanding from [Redacted] 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... 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.

From: [Redacted] (NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03

[Page 9]
Subject: Re: Epstein search warrant documents
[Redacted],
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 (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 [Redacted] 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.

From: [Redacted]
Sent: Tuesday, May 12, 2020 11:33 AM
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...

[Page 10]
Like [Redacted] said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a particular device. Problem now is how to get the data to [Redacted] since he is teleworking.

From: [Redacted] (NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem. [Redacted] and I ironed out all the details. We've got a good plan moving forward that will meet your needs.

On May 12, 2020 10:34 AM, [Redacted] wrote:
[Redacted], 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... In terms of data transfer, [Redacted] are you just sending a literal copy of all the raw data, and we'll process and upload it on our end?

From: [Redacted] (USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
Subject: RE: Epstein search warrant documents
Hello [Redacted],

[Page 11]
Me and [Redacted] just finished our phone call regarding the data. [Redacted] 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 [Redacted] so he can begin to copy the data and send it to us.

From: [Redacted]
Sent: Friday, May 8, 2020 2:15 PM
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: [Redacted] (NY) (FBI)
Sent: Friday, May 08, 2020 14:14
Subject: RE: Epstein search warrant documents
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.

On May 8, 2020 1:58 PM, [Redacted] wrote:
Understood, thanks—it will be great to get that list on Thursday... On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete transmission of the search warrant returns is no longer likely?

[Page 12]
From: [Redacted] (NY) (FBI)
Sent: Friday, May 08, 2020 13:50
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 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.

On May 8, 2020 12:10 PM, [Redacted] wrote:
[Redacted],
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... We're waiting on that list to be able to do an updated search warrant on all of those devices.

From: [Redacted] (NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
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.

From: [Redacted]
Sent: Tuesday, April 07, 2020 3:15 PM

[Page 13]
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow...

From: [Redacted] (NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
Subject: RE: Epstein search warrant documents
[Redacted],
Are you available tomorrow for a conference call to discuss this issue?
SSA [Redacted]
FBI New York

On Apr 7, 2020 1:55 PM, [Redacted] 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...

From: [Redacted]
Sent: Monday, March 09, 2020 12:00
Subject: RE: Epstein search warrant documents

[Page 14]
[Redacted],
Unfortunately I don't think this is very helpful to us... The excel file you sent has descriptions that don't match up to the items listed in the search warrant returns... 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.
- The load file has no link to the native file... 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.

From: [Redacted] (NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
Subject: RE: Epstein search warrant documents
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.

[Page 15]
Spreadsheet is attached.
NYO CART Coordinator

From: [Redacted]
Sent: Tuesday, March 03, 2020 12:25 PM
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?

From: [Redacted] (NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
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.

On Mar 2, 2020 11:15 AM, [Redacted] wrote:
Doing the weekly check in on this – is there a time this week when everyone can meet on this?

From: [Redacted]
Sent: Monday, February 24, 2020 17:38

[Page 16]
Subject: RE: Epstein search warrant documents
[Redacted],
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... 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...

From: [Redacted] (NY) (FBI)
Sent: Monday, February 24, 2020 09:24
Subject: RE: Epstein search warrant documents
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 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.

On Feb 23, 2020 12:21 AM, [Redacted] wrote:
Team,
Following up on the below from last weekend... We didn't hear back on which files had previously been provided... 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

[Page 17]
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.

From: [Redacted]
Sent: Saturday, February 15, 2020 16:30
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this... I have the hard drive that [Redacted] dropped off that has new Epstein search warrant materials... Just generally... 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...
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified date of 11/14/19... And then there's another folder titled "NYC024362" that has a modified date of 1/27/20... That folder by itself has more than 600,000 items.
Assistant U.S. Attorney