EFTA00029487.pdf
99.2 KB
Extraction Summary
3
People
5
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Email chain
File Size:
99.2 KB
Summary
This document is an internal US Attorney's Office (SDNY) email chain dated October 30, 2020, discussing a critical delay in discovery production for the 'US v. Epstein' case. Nicholas Koontz, a lead analyst at contractor PAE, informs the team that 1.2 million records are still being imaged and won't be available until November 2. USANYS staff express frustration that requests made in September are only just arriving, concluding they will likely miss a November 9 deadline set by Judge Nathan.
People (3)
| Name | Role | Context |
|---|---|---|
| Nicholas D. Koontz | Lead E-Discovery Analyst, PAE |
Sender of the initial email detailing discovery production status and delays.
|
| Judge Nathan | Judge |
Federal judge overseeing the case; USANYS staff are concerned about missing a deadline set by her.
|
| Redacted USANYS Staff | Attorneys/Staff |
Multiple redacted individuals from US Attorney's Office NY South discussing the delay.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| USANYS |
United States Attorney's Office for the Southern District of New York
|
|
| PAE |
Government contractor handling E-Discovery processing
|
|
| SDNY |
Southern District of New York (recipient of the hard drive)
|
|
| FedEx |
Courier service used to ship the hard drive
|
|
| Relativity |
E-Discovery software platform mentioned
|
Locations (2)
| Location | Context |
|---|---|
|
Location of PAE office/Nicholas Koontz
|
|
|
New York, destination for discovery materials
|
Relationships (2)
Koontz (PAE) providing discovery data to USANYS
USANYS litigating case before Judge Nathan, concerned about deadlines
Key Quotes (5)
"We will most likely not meet the November 9 deadline."Source
EFTA00029487.pdf
Quote #1
"The problem is the stuff that is coming today is stuff the team asked PAE to process in early September."Source
EFTA00029487.pdf
Quote #2
"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."Source
EFTA00029487.pdf
Quote #3
"I am concerned about requiring our team to take the hit with Judge Nathan for missing this deadline."Source
EFTA00029487.pdf
Quote #4
"There are approximately 1.2 million records currently being imaged."Source
EFTA00029487.pdf
Quote #5
Full Extracted Text
Complete text extracted from the document (3,366 characters)
From: [REDACTED] (USANYS) <[REDACTED]>
To: [REDACTED] (USANYS)" <[REDACTED]>
Subject: RE: Phone Call Follow-Up
Date: Fri, 30 Oct 2020 20:15:45 +0000
Inline-Images: image001.png
To: [REDACTED] (USANYS)" <[REDACTED]>
Subject: RE: Phone Call Follow-Up
Date: Fri, 30 Oct 2020 20:15:45 +0000
Inline-Images: image001.png
Not good.
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Friday, October 30, 2020 2:45 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Subject: FW: Phone Call Follow-Up
Sent: Friday, October 30, 2020 2:45 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Subject: FW: Phone Call Follow-Up
We will most likely not meet the November 9 deadline.
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Friday, October 30, 2020 2:41 PM
To: [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Subject: RE: Phone Call Follow-Up
Sent: Friday, October 30, 2020 2:41 PM
To: [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
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
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.
[REDACTED]
From: Koontz, Nicholas [US] <[REDACTED]>
Sent: Friday, October 30, 2020 12:25 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] (USANYS) [Contractor] <[REDACTED]>
Subject: Phone Call Follow-Up
Sent: Friday, October 30, 2020 12:25 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] (USANYS) [Contractor] <[REDACTED]>
Subject: Phone Call Follow-Up
Good Afternoon [REDACTED]:
EFTA00029487
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
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,
Nick
Nicholas D. Koontz
Lead E-Discovery Analyst
Lead E-Discovery Analyst
[REDACTED]
Falls Church, Virginia 22043
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-#
EFTA00029488
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