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EFTA00028688.pdf

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Extraction Summary

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

Document Information

Type: Email chain
File Size: 91.7 KB
Summary

An email chain from October 30, 2020, between the US Attorney's Office (SDNY) and PAE (an e-discovery contractor). The correspondence concerns the shipment of hard drives containing productions SDNYPROD008 through SDNYPROD014 for the 'US v. Epstein' workspace. The USANYS staff expresses serious concern regarding processing delays (taking 1-2 months), the volume of data (1.2 million records), and the high likelihood of missing a November 9 deadline set by Judge Nathan.

People (3)

Name Role Context
Ed Recipient (USANYS)
Addressed in the 12:25 PM email regarding the delivery of hard drives.
Judge Nathan Judge
Mentioned as the judge overseeing the case; concern expressed about missing a deadline set by her.
Lead E-Discovery Analyst Sender (PAE)
Sent the initial update regarding the hard drive shipment and imaging status.

Organizations (5)

Name Type Context
USANYS
United States Attorney's Office for the Southern District of New York; the prosecuting office.
PAE
Contractor handling E-Discovery and data processing.
FedEx
Courier service used to transport the hard drive.
Relativity
E-discovery software platform mentioned regarding data retrieval.
SDNY
Southern District of New York (Court/Office).

Timeline (2 events)

2020-11-02
Earliest availability of images for 1.2 million records.
US v. Epstein workspace
PAE
View
2020-11-09
Discovery Deadline
Court
USANYS Judge Nathan
View

Locations (2)

Location Context
7799 Leesburg Pike, Suite 300N, Falls Church, Virginia 22043
Address for PAE (E-Discovery Analyst).
SDNY
Destination for the hard drive.

Relationships (2)

USANYS → Client/Contractor → PAE
USANYS asking PAE to process data; PAE sending invoices/productions.
USANYS → Legal/Court → Judge Nathan
USANYS concern about explaining delays to Judge Nathan.

Key Quotes (5)

"The problem is the stuff that is coming today is stuff the team asked PAE to process in early September."
Source
EFTA00028688.pdf
Quote #1
"I am concerned about requiring our team to take the hit with Judge Nathan for missing this deadline."
Source
EFTA00028688.pdf
Quote #2
"There are approximately 1.2 million records currently being imaged."
Source
EFTA00028688.pdf
Quote #3
"He thinks it is not possible to meet the November 9 date."
Source
EFTA00028688.pdf
Quote #4
"Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via FedEx with the following productions in the US v. Epstein workspace"
Source
EFTA00028688.pdf
Quote #5

Full Extracted Text

Complete text extracted from the document (3,159 characters)

From: [REDACTED] (USANYS)" <[REDACTED]>
To: [REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>
Subject: RE: Phone Call Follow-Up
Date: Fri, 30 Oct 2020 18:42:13 +0000
Inline-Images: image001.png
Understood
From: [REDACTED] (USANYS)
Sent: Friday, October 30, 2020 2:41 PM
To: [REDACTED] (USANYS) ; [REDACTED] (USANYS)
Subject: RE: Phone Call Follow-Up
Thanks, [REDACTED]. The problem is the stuff that is coming today is stuff the team asked PAE to process in early September. I realize that this is a big project and that there's only so much that can be done, but it poses almost insurmountable timing hurdles for our team if it is taking 1-2 months for PAE to get us stuff we ask for out of Relativity. In most of our cases, this one included, that eats up a huge chunk of the time we have available to produce discovery.
We'll follow up early next week to see if there is a more concrete update, but I think this may require a broader or higher level explanation to the Court. I am concerned about requiring our team to take the hit with Judge Nathan for missing this deadline.
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Friday, October 30, 2020 12:51 PM
To: [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Subject: FW: Phone Call Follow-Up
Some of the data is being sent to use today by FedEx. However, there is a ton of stuff still being processed. That stuff is still being imaged. Then it gets marked. Then copied to us. I have spoken to [REDACTED]. He thinks it is not possible to meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion might be possible.
From: [REDACTED] [US] <[REDACTED]>
Sent: Friday, October 30, 2020 12:25 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] (USANYS) [Contractor] <[REDACTED]>
Subject: Phone Call Follow-Up
Good Afternoon Ed:
Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via FedEx with the following productions in the US v. Epstein workspace:
1) SDNYPROD008
2) SDNYPROD009
3) SDNYPROD010
4) SDNYPROD011 (Note: this is a six-part production)
5) SDNYPROD012
6) SDNYPROD013
7) SDNYPROD014
There are approximately 1.2 million records currently being imaged. The images will be available on Monday, November 2, 2020 at the earliest. The production of the records will begin as soon as the images are available in the workspace.
Please feel free to contact me if you have any questions.
Thanks,
[REDACTED]
[Page 2]
Lead E-Discovery Analyst
e. [REDACTED]
7799 Leesburg Pike, Suite 300N
Falls Church, Virginia 22043
PAE
IMPORTANT: The information contained in this message may be privileged, business sensitive, proprietary, copyrighted, protected from disclosure and/or subject to US export controls. If you are not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify me immediately by replying to the message and deleting it from your computer. #-SEC-#
EFTA00028688
EFTA00028689
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