EFTA00029025.pdf

257 KB

Extraction Summary

5
People
7
Organizations
3
Locations
2
Events
2
Relationships
5
Quotes

Document Information

Type: Email correspondence / discovery log
File Size: 257 KB
Summary

This document is a chain of emails from September 2020 between the US Attorney's Office (SDNY) and contractors regarding the discovery process in the US v. Epstein/Maxwell case. The correspondence details the technical logistics of uploading roughly 40,000 files (300GB), labeled as 'Images Seized During Search', to the Relativity database. Key topics include handling native file formats (Excel/Text), verifying if Ghislaine Maxwell can open these files on BOP computers at the MDC, and managing confidential stamping for the production. References are also made to productions involving Deutsche Bank and JPMorgan.

People (5)

Name Role Context
Ghislaine Maxwell Defendant
Subject of the discovery production; discussion about her ability to open files at MDC.
Jeffrey Epstein Subject of case
Referenced in case name 'US v. Epstein' and folder path.
[Redacted] Paralegal Specialist
US Attorney's Office SDNY employee initiating the upload request.
[Redacted] USANYS Contractor
Multiple contractors involved in the technical aspects of data upload and production.
[Redacted] BOP Employee
Contacted regarding text reader capabilities at the Bureau of Prisons.

Timeline (2 events)

2020-09-17 through 2020-09-25
Processing and uploading of 'Images Seized During Search' (40,000 files, 300GB) to the Relativity database for discovery production in US v. Epstein/Maxwell.
Digital (Relativity)
USANYS Staff PAE Contractors
2020-09-24
Export of Deutsche Bank and JPMorgan productions to the shared drive.
Digital
USANYS Contractors

Relationships (2)

Ghislaine Maxwell Defendant/Prosecution USANYS
Discussions about producing discovery documents to her at MDC.
PAE Vendor/Client USANYS
PAE hosting the Relativity database used by USANYS for document review.

Key Quotes (5)

"If Maxwell has trouble opening them at MDC, we'll deal with that after she tells us she can't open them."
Source
EFTA00029025.pdf
Quote #1
"The files in question number about 40,000 and are about 300GB in size."
Source
EFTA00029025.pdf
Quote #2
"Folder/Subfolder in Relativity: US v. Epstein -> FBI Case File -> Images Seized During Search"
Source
EFTA00029025.pdf
Quote #3
"Apparently, their computers are equipped with text readers (as suspected)."
Source
EFTA00029025.pdf
Quote #4
"No way to put a confidential stamp on a excel file. There should be an image placeholder that says document produced in native format which has the confidential stamp."
Source
EFTA00029025.pdf
Quote #5

Full Extracted Text

Complete text extracted from the document (8,476 characters)

From: [Redacted] (USANYS) [Contractor] <[Redacted]>
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
Date: Fri, 25 Sep 2020 15:23:40 +0000
Great point, thanks!
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Friday, September 25, 2020 11:22 AM
To: [Redacted]
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
Okay great. I reached out to [Redacted] at BOP to get an answer on their text reader capabilities. Apparently, their computers are equipped with text readers (as suspected). I'm still waiting to hear back on the specific program(s) that they use. I figured it would be useful to know and/or include in the next discovery cover letter so that defense can't claim that she has no capability to open those files.
From: [Redacted]
Sent: Friday, September 25, 2020 11:18 AM
To: [Redacted] (USANYS) [Contractor]
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
Thanks for flagging. Let's produce in their original format to both for now. If Maxwell has trouble opening them at MDC, we'll deal with that after she tells us she can't open them. She has not identified every single excel and txt file from past productions as problematic, so she will hopefully be able to open these.
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Friday, September 25, 2020 10:47 AM
To: [Redacted] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
How are we handling producing to Maxwell vs. Counsel? With these files there are tons of text and excel files that need to be converted in order to be sent to MDC. Are we also producing the converted versions to defense or rather the original natives?
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Thursday, September 24, 2020 2:34 PM
To: [Redacted] (USANYS) [Contractor]
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
The zip files have been copied to the below location. Please let me know if there are any issues with the data in the zip files.
Thank you.
[Redacted]
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Thursday, September 24, 2020 11:42 AM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
That's what I figured. Thanks! Now that they are all good to go would you please export both Deutsche Bank and JPMorgan productions to the shared here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\04 Fourth Production\TO BE PRODUCED
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Thursday, September 24, 2020 11:39 AM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
No way to put a confidential stamp on a excel file. There should be an image placeholder that says document produced in native format which has the confidential stamp.
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Thursday, September 24, 2020 11:36 AM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
Thanks [Redacted]. These look great. One quick question, on documents in native format (excel files) is there a confidential stamp? I've checked and it seems the answer is no but I just want to be sure that I'm not missing anything.
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Thursday, September 24, 2020 11:20 AM
To: [Redacted] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
The documents should now be available for review. Please let me know if there are any questions.
Thank you.
[Redacted]
From: [Redacted] <[Redacted]>
Sent: Thursday, September 24, 2020 9:11 AM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) [Contractor]
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
These documents are not supposed to be privileged reviewed. The only documents that need to be privilege reviewed are the electronic search warrant returns.
Thanks,
[Redacted]
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Thursday, September 24, 2020 9:05 AM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
The data is probably secured for privilege review. Please let me know if these documents are not supposed to be privileged reviewed.
Thank you.
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Wednesday, September 23, 2020 5:39 PM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
Hey [Redacted],
When I click on each of those links I'm brought to a Relativity page with no data. Am I doing something wrong?
Thanks,
[Redacted]
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Wednesday, September 23, 2020 11:32 AM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
The production of the documents has been completed. The below are links to the production for you to review:
Deutsche Bank - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343058
JP Morgan - https://dlpe.nss.pae.com/Relativity/go?id=1420850-2343059
Please review the documents and let me know if anything needs to be adjusted with the production.
Thank you.
[Redacted]
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Friday, September 18, 2020 10:26 AM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
1. Yes, we want to mark all of them confidential
2. We are working on that.
3. I suppose database load files? We want to retain the files as they are currently formatted as best we can.
4. That won't be an issue. I don't think we will be searching through them; the purpose is just to be able to stamp them.
Thanks!
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Friday, September 18, 2020 10:10 AM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: RE: Epstein/Maxwell Upload
I know you want to produce these documents can you please tell me the following:
1. Will you placing a Confidential stamp on these documents?
2. What bates number do you wish to use on the documents?
3. How do you want to produce the documents (single page tiff images, database load files or PDF production).
4. Also please note that once the documents have been loaded to Relativity there is no way to run any searches for these images since they are mostly images and video.
Please let me know if there are any questions.
Thank you.
[Redacted]
From: [Redacted] (USANYS) [Contractor] <[Redacted]>
Sent: Thursday, September 17, 2020 4:54 PM
To: [Redacted] (USANYS) [Contractor] <[Redacted]>
Cc: [Redacted] (USANYS) [Contractor] <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Subject: Epstein/Maxwell Upload
Hey [Redacted],
We have some materials that we need uploaded to Relativity to the Epstein database for the purpose of stamping them.
The files in question number about 40,000 and are about 300GB in size. They are currently copying onto a drive to be sent to Relativity and should be ready by tomorrow. Do you want to see them first or can they go directly to PAE?
Folder/Subfolder in Relativity: US v. Epstein -> FBI Case File -> Images Seized During Search
Thanks,
[Redacted]
[Redacted]
Paralegal Specialist
U.S. Attorney's Office | SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office: [Redacted]
Cell: [Redacted]
EFTA00029025
EFTA00029026
EFTA00029027
EFTA00029028
EFTA00029029

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