DOJ-OGR-00001818.jpg
981 KB
Extraction Summary
3
People
5
Organizations
4
Locations
5
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / court filing (letter motion)
File Size:
981 KB
Summary
This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan requesting a two-week extension (until Nov 23, 2020) to produce electronic discovery in the case against Ghislaine Maxwell. The delay is attributed to an outside vendor needing more time to process data from electronic devices seized by the FBI from Jeffrey Epstein's residences in NY and the Virgin Islands in 2019. The letter details the history of the data seizure, privilege reviews requested by Epstein's estate, and mentions that over 350,000 pages of discovery have already been produced.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
Honorable Judge of the United States District Court, recipient of the letter.
|
| Ghislaine Maxwell | Defendant |
Defendant in the referenced case (United States v. Ghislaine Maxwell).
|
| Jeffrey Epstein | Deceased Subject |
Source of the electronic devices seized by the FBI from which discovery is being produced.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Sender of the document, represented by the United States Attorney.
|
|
| United States Attorney, Southern District of New York |
Prosecuting office filing the request.
|
|
| United States District Court |
Court handling the case.
|
|
| Federal Bureau of Investigation (FBI) |
Law enforcement agency that seized the electronic devices.
|
|
| Epstein's Estate |
Entity that requested a filter team review for privileged materials.
|
Timeline (5 events)
August 2019
FBI searched Epstein's residence in the Virgin Islands and seized electronic devices.
U.S. Virgin Islands
FBI
Jeffrey Epstein
February 2020
Privilege team completed review of data subset; Government initiated responsiveness review.
Unknown
Filter Team
Government
July 2019
FBI conducted multiple searches of Epstein's residence in New York and seized electronic devices.
New York, NY
FBI
Jeffrey Epstein
June 26, 2020
Government obtained a new warrant expanding the scope.
Unknown
Government
Locations (4)
| Location | Context |
|---|---|
|
Address of the U.S. Attorney: One Saint Andrew's Plaza, New York, New York 10007.
|
|
|
Address of the Court: 40 Foley Square, New York, New York 10007.
|
|
|
Location where FBI conducted searches in July 2019.
|
|
|
Location where FBI conducted searches in August 2019.
|
Relationships (2)
Maxwell is the defendant in a case where discovery involves devices seized from Epstein's residences.
The Estate requested a privilege review of data seized from Epstein.
Key Quotes (5)
"The Government respectfully submits this letter to request an extension of the deadline for the production of a subset of the electronic discovery... from November 9, 2020 to November 23, 2020."Source
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Quote #1
"This extension is necessary solely to allow adequate time for an outside vendor to finalize the preparation of documents extracted from electronic devices seized from Jeffrey Epstein for production."Source
DOJ-OGR-00001818.jpg
Quote #2
"To date, the Government has produced more than 350,000 pages of discovery to the defense over the course of five productions"Source
DOJ-OGR-00001818.jpg
Quote #3
"Specifically, in July of 2019, the FBI conducted multiple searches of Epstein’s residence in New York, and in August of 2019, the FBI searched Epstein’s residence in the Virgin Islands."Source
DOJ-OGR-00001818.jpg
Quote #4
"At the request of Epstein’s estate, a filter team conducted a review of that subset of data for potentially privileged materials."Source
DOJ-OGR-00001818.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (3,000 characters)
Case 1:20-cr-00330-AJN Document 69 Filed 11/06/20 Page 1 of 4
U.S. Department of Justice
U.S. Department of Justice
United States Attorney
Southern District of New York
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
One Saint Andrew’s Plaza
New York, New York 10007
November 6, 2020
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter to request an extension of the deadline for the production of a subset of the electronic discovery in the above-referenced case from November 9, 2020 to November 23, 2020. This extension is necessary solely to allow adequate time for an outside vendor to finalize the preparation of documents extracted from electronic devices seized from Jeffrey Epstein for production. Over the past two days, the Government has conferred with defense counsel, who indicated this morning that they would only consent to the extension on four conditions, detailed below. Although the Government agrees to meet two of the defense conditions, it will not agree to the other two, which have no connection to the delay in discovery and no basis in law. Accordingly, the Government respectfully requests that the Court grant the extension to produce electronic discovery to November 23, 2020.
To date, the Government has produced more than 350,000 pages of discovery to the defense over the course of five productions, and the Government expects to make a sixth production by the existing November 9, 2020 deadline, as detailed below. However, the Government’s outside vendor has advised the Government that it requires additional time to prepare a seventh and final production of electronic discovery. By way of background, that final production comes from electronic devices that the Federal Bureau of Investigation (“FBI”) seized from Jeffrey Epstein’s residences in New York and the U.S. Virgin Islands in 2019. Specifically, in July of 2019, the FBI conducted multiple searches of Epstein’s residence in New York, and in August of 2019, the FBI searched Epstein’s residence in the Virgin Islands. During both searches, the FBI seized dozens of electronic devices. Pursuant to court-authorized warrants, the FBI then initiated the months-long process of gaining access to and extracting data from those devices.
In or about January of 2020, the FBI provided some, but not all, of the data from those devices to the Government. At the request of Epstein’s estate, a filter team conducted a review of that subset of data for potentially privileged materials. In or about February of 2020, the privilege team completed its review of a subset of data that the FBI had provided. In or about late February of 2020, the Government initiated a responsiveness review of that subset of data.
On June 26, 2020, the Government obtained a new warrant expanding the scope of the
DOJ-OGR-00001818
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