EFTA00032141.pdf

From: ' 1 To: 1 Subject: FW: Epstein search warrant documents Date: Tue, 31 Mar 2020 17:02:32 +0000 Embedded: Epstein_terms jor_privilege_review.insg Just FYI From: Sent: Tuesday, March 31, 2020 13:02 To: (NY) (FBI)' <spwatson@fbi.gov> Subject: RE: Epstein search warrant documents Hey =, So far so good here, thanks — just trying to deal with the tech issues of working from home (not to mention the inability to interview witnesses!) but really can't complain at all, the girlfriend and I are both healthy and distancing. Hope that's true for you and yours too. In terms of the issues below, unfortunately there isn't any progress — it's not a delay on our end, we've run the taint screen and so the AUSAs and agents all have access on Relativity to the materials that sent over in December. We also sent the privilege taint terms to the agents a couple weeks ago so they could run the screen on whatever programs they may be using — that's attached. We hadn't realized that they were impeded on their review due to any taint issue, we just thought they were using Relativity, same as us. More generally though, the issue we continue to have is the same one since February. We have absolutely no sense of what sent to us — it's not organized or identified by device or even by location, the documents aren't joined with their attachments (their "families" in the terms of doc review), we can't look at native files, etc. It's all the issues from my March 9 email, below, which never responded to. And it's only 1.4 million documents out of what are presumably tens of millions total — we haven't gotten any version of the rest (and don't know exactly what we're missing, because again, we have no way to track what we've been given so far). If (and/or others at CART) are teleworking, it would be great to get help on this, because obviously weeks are going by that we could be using to review. I had been trying to push my chiefs for a meeting in early March but then obviously the world imploded! So not sure what can be done currently, but happy to discuss with anybody that would be useful. thanks as always, From: (NY) (FBI) <spwatson@fbi.gov> Sent: Monday, March 30, 2020 13:23 To: Subject: RE: Epstein search warrant documents hope you are doing well and more importantly feeling well! Just checking and on the status of everything, is that issue with the taint review is still on going? I'm assuming you're doing a fair amount of tele working SSA EFTA00032141 FBI New York On Mar 11, 2020 2:05 PM, ' (NY) (FBI)" <spwatson@fbi.gov> wrote: Let's get together and hash it out, let me know what works for you this week and next and I'll get Flatley and my team there as well. From: ) (mailto Sent: Wednesday, March 11, 2020 12:03 PM To: (NY) (FBI) <spwatson@fbi.gov> Subject: RE: Epstein search warrant documents = totally happy to chat, and it's exactly the same issues as we talked about on the phone a couple weeks ago when we first raised this -- I wonder if it makes sense to get in a room together? Otherwise it's a lot of games of telephone. But basically the way to think about it is, imagine if we had seized papers from approximately 100,000 filings cabinets in a dozen different office buildings. And then instead of keeping them organized or labeled by room, or even by office building, all 1.3 million documents (so far) just got dumped into one big pile — except before that, any documents that had multiple parts stapled together got separated. And then if any of those documents that was larger than about 100 pages couldn't be opened. That's what we've got, just electronically. From: (NY) (FBI) <spwatson@fbi.gov> Sent: Wednesday, March 11, 202011:15 To: Subject: RE: Epstein search warrant documents ca) I was out yesterday, let's touch base so we can get this resolved. I'm confused as to what is going on here, sounds like there are issues that you haven't been able to resolve by going direct with Flatley. Thanks, From: [mailto Sent: Monday, March 09, 2020 12:00 PM To: . (NY) (FBI) <->; (NY) (FBI) <spwatson@fbi.gov>, (USANYS) Cc: (USANYS) [Contractor] <Christopher.Rozier@usdoj.gov>• (USANYS) <S) Subject: RE: Epstein search warrant documents (NY) (FBI) <M > Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on 2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by "loose media" without a specific comparison to what was seized, we don't know which items you're referring to as "Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial. For example, it looks like we have gotten very, very few image files, which is surprising. We have also encountered some very significant problems in trying to review the more than 1 million documents we recently received: EFTA00032142 The data we've received has no way to put any emails and attachments together. So if an email says, "see the attached flight records," for example, we have no way of linking that up with the records themselves. Not only is that a big problem for us in review, it's going to be a huge problem for producing the documents to defense counsel. The load file has no link to the native file, so when we load the data to the database, there's no way to have the native files show up in the database. Because many of the files are too large to open in the viewer, it effectively means that there are many files that are completely invisible to us. Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers and no way to match up anything—that is, even if we were to try to go hunt down every individual large file in the native files, it would be impossible. So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million documents without much rhyme or reason. I've re-attached the spreadsheet we sent last week — I think that's a good place to start in terms of our necessary record-keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful. thanks, From: (NY) (FBI) <> Sent: Wednesday, March 04, 2020 16:36 To: (NY) (FBI) <spwatson@fbi.gov>• (USANYS) Cc: (USANYS) [Contractor] <CRozier@usa.doj.gov>; (FBI) ca° Subject: RE: Epstein search warrant documents (USANYS) >; (NY) Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2 Macs from NY and 1 from the Island are included. I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool they have to be processed with does not easily re-name the load files. Spreadsheet is attached. NYO CART Coordinator Senior Forensic Examiner From: 1 [mailto: Sent: Tuesday, March 03, 2020 12:25 PM 1 EFTA00032143 To: • (NY) (FBI) ce (NY) (FBI) <spwatson@fbi.gov>; (USANYS) (USANYS) Cc: (USANYS) [Contractor] <Christopher.Rozier@usdoj.gov>• ; Subject: RE: Epstein search warrant documents (NY) (FBI) 'c=w