EFTA00028585.pdf

From: ' )" To: 'il ANYS)" Subject: FW: Discovery Issues Date: Wed, 12 May 2021 13:55:32 +0000 Inline-Images: image001.jpg; image002.jpg )" You two are welcome to join, but no pressure. I'm happy to handle. From: (USANYS) [Contractor] < Sent: Wednesday, May 12, 2021 9:43 AM To: (USANYS) [Contractor] c Cc: ) <a; (USANYS) [Contractor] la; (USANYS) Subject: Re: Discovery Issues As am I. On May 12, 2021, at 9:36 AM, From: Sent: Tuesday, May 11, 2021 10:41 PM To: (USANYS) [Contractor] (USANYS) [Contractor] • Cc: Subject: FW: Discovery Issues and I are both available anytime today. (USANYS) [Contractor] <M> wrote: < Hi team, (USANYS) [Contractor] (USANYS)<M > Maxwell's attorneys have asked for the below-listed information from the SUPP production that went out on November 9, 2021. Is there a time tomorrow when we can have a call to discuss, please? Thanks, From: Laura Menninger < Sent: Friday, May 7, 2021 4:53 PM To: clI M:; Christian Everdell < M>; Cc: Jeff Pagliuca Subject: RE: Discovery Issues (USANYS) ; Bobbi Sternheim ( Also following up on your response to Chris. We have had a chance to take a look at these files again. EFTA00028585 For the SUPP production, many of the files were produced as PDFs, which seems as though they were converted prior to production. As I understand it (which is admittedly limited), carved or deleted files can still contain application metadata. We request that as to the SUPP production, you: a. Provide a list of all files that were carved or deleted; b. Confirm if all those files were produced in native format or if any were converted to PDF; c. If any were converted, provide additional information including the MIME type (for all), and if available from application metadata original file name, file dates, etc. This would amount to the equivalent of the index you provided for SDNY011. d. In the absence of (b), confirm that no application metadata was recovered from those files which might indicate file creation/modified dates Please let me know if you have any questions. Thanks, Laura Laura A. Henninger I Partner Haddon, Mor an & Foreman, P.C. From: Sent: Friday, April 23, 2021 10:30 AM To: Christian Everdell (Office) (usANYs) Cc: Jeff Pagliuca ; Laura Menninger < ; Bobbi Sternheim Subject: RE: Discovery Issues Chris, Following up on these issues: • For #3, the attachments were not recovered from the searched devices. We do not have them, which is why they were not produced. • For #4, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data showing when a particular file was saved to a drive by the investigative team or prepared for production. I am not aware of any additional metadata in our possession that you do not have for these files. • For #5, those photographs were not processed by CART, which is why they do not have a CART number. They came from the CDs that your team reviewed last week. The available metadata for those photographs was produced in two excel spreadsheets with the same production — one with metadata for nude images (which were contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet. • For #6: EFTA00028586 o The SDNY_GM_SUPP contain electronic files recovered from Epstein's devices. As noted above, those files have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable. o The videos from SDNY005 (October 20, 2020 production) were converted by a vendor from VHS and cassette tapes, so there is no metadata to provide. The Sept-Octo 2020 dates reflect when these recordings were converted by our vendor. o The SDNY011 (November 9, 2020 production) consists of images from the CDs seized from Epstein's residences, which you reviewed last week. As referenced above, those photographs were not processed by CART, which is why they do not have a CART number. As referenced above, the available metadata for those photographs was produced in two excel spreadsheets with the same production — one with metadata for nude images (which were contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet. Best, Assistant United States Attorney Southern District of New York From: Sent: Tuesday, March 30, 2021 11:10 PM To: Christian Everdell c> (USANYS) Cc: 'Jeff Pagliuca' ) Subject: RE: Discovery Issues Chris, ; Laura Menninger Bobbi Sternheim That all makes sense, thanks very much. I will reach back out once I have conferred with our vendor and have answers for you on #3-#6. Best, Assistant United States Attorney Southern District of New York EFTA00028587 From: Christian Everdell < Sent: Tuesday, March 30, 2021 10:58 PM To: ) < (USANWS) Cc: 'Jeff Pagliuca' >; ; Laura Menninger >; Bobbi Sternheim Subject: RE: Discovery Issues Apologies for the late response on this. It seems like it would be better to confer after you have heard back from your vendor, since the answers to #3-#6 will depend on what the vendor says. And I believe we have now resolved #7. As for #1 and #2, I will cal at MDC and represent to her that we have your concurrence to send the drive directly to Ms. Maxwell. If she agrees, we can add the additional productions to our drive before we send it. If she refuses, we will take it up with Judge Nathan. Thanks, Chris From: Sent: Monday, March 29, 2021 3:36 PM To: Christian Everdell; ); In=11.1.SYNA. Cc: 'leff Pagliuca'; Laura Menninger; Bobbi Sternheim Subject: RE: Discovery Issues Chris, We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial responses: 1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC legal counsel the opportunity to note their objections to Judge Nathan. 2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive if you would like to provide one for us. 3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. 4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except