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RE: Discovery questions

16 messages picture_as_pdf Source PDF
[
[Redacted] Aug 18, 2020 4:33 AM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Hi and

Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent batch you provided, and wanted to check in on the longer term tasks we discussed last month.

Below are some questions regarding the discovery dropped off a few days ago with requests for additional items: [ ]

• The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it contains grand jury transcripts. Have you given us those transcripts?

• The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad—and those copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad scans" folder. Would you please get us a scans of these without post-its on them?

• It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant. Would you please get us copies of those returns?

Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you please be able to get us these this week?

• Full FBI sentinel file

• CART paperwork regarding the extraction of data from all devices seized during the investigation

• All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard copy) seized during the investigation, including from Epstein's properties.

• Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials

• Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how many such images were scanned, where they were from, and where they are being stored.

• Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how many such images were located, where they were from, and where they are being stored.

Please let me know if you have any questions or if it would be useful to hop on a call.

[
[Redacted] Aug 18, 2020 4:40 AM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went through for so she can see it. If not, please let me know.

Thanks,

[
[Redacted] Aug 18, 2020 4:45 AM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Sorry, got a bounceback for
will go through.

too. I'm just attaching the one page I referenced in my email below. Hopefully that

[
[Redacted] Aug 18, 2020 4:41 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Hi and

The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to provide us with all of those scans this week?

With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes on them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans.

Thanks,

[
[Redacted] Aug 18, 2020 6:03 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these materials tomorrow or Thursday?

Thanks,

[
[Redacted] Aug 18, 2020 6:40 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Hey guys,

Apologies but today I was out In the field on surveillance and was also out of the office so we've not been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best to get on this list. That being said I don't want to make you any promises that everything will be compiled by tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if you like to square some of this away.

I did receive your "pages from Miami_case_docs" PDF.

[
[Redacted] Aug 18, 2020 6:41 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Thanks so much,M. Really appreciate all the work you and are putting in on this. Let's touch base tomorrow to figure out the timeline for the discovery issues.

F
FBI (NY) Aug 19, 2020 2:21 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Hey all, below is a summary of the discovery items you've requested.

Message Pad Scans: The message pads were scanned with the post it notes on them and the very next page is the page without the post it note, so the pages are back to back.

Papers from Miami case file (grand jury testimony): This is a disk — I can copy it and send it over to you.

Evidence scans: Are you referring to the scans from the FL file? We sent those over with the original message pad scans last year. If you need that again, let us know and we can get another copy over to you. As far as paper evidence from

the NY and VI searches, and the paper provided by Reiter, we can get that over to you by the end of the week.

FBI file: We have that ready for you.

CART: There are no 302s regarding the extraction of devices.

Evidence from disks: This is a large volume and we've been working on this and removing nude/semi nude images. This is the only thing that would be difficult to complete by Friday. If we could have a little more time to pull this together, that would be very helpful.

If it's helpful to talk through some of this via phone, we are happy to do that as well.

[
[Redacted] Aug 19, 2020 7:01 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Thank you so much for these—very helpful (and sorry I didn't realize the message pad scans also had the same pages without post-its!)

On these:

• Yes, please send over the copy of the gj transcript disc when you can.

• Found the original scans from the FL file—thank you!

• Yes, please get us the paper evidence from NY, VI, and Reiter as soon as you can.

• We'll take the FBI file whenever you can get it to our office.

• My understanding from past FBI cases is that CART completes some sort of paperwork documenting the dates on which they conduct data extractions. We need that for all of the extractions in this case, please (It may not be 302s).

• On the evidence from disks, understood. In order to give you more time, we are going to tell the defense attorneys that the materials are available for them to review in-person if they want to schedule a time to come down to the FBI office, but that in the meantime we are still working on getting copies of non-nude images to produce to them.

[
[Redacted] Aug 19, 2020 7:20 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

That sounds great. Thank you. We are definitely open to them scheduling a time if need be.

I will check in with CART again and get back to you.

[
[Redacted] Aug 19, 2020 7:22 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Perfect, thanks! Yes, I think we should take the vhs tapes and microcassettes to get them converted, if that's ok.

[
[Redacted] Aug 19, 2020 7:24 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

Sure no problem. I can bring those over tomorrow as well.

[
[Redacted] Aug 19, 2020 8:43 PM
To
[Redacted]
Cc
[Redacted][Redacted] (NY) (FBI)[Redacted] (USANYS)

I'll be in the office tomorrow.

Sent from my iPhone

F
FBI (NY) Aug 20, 2020 6:17 PM
To
[Redacted]
Cc
[Redacted] (USANYS)

Hey all,

Just wanted to send a quick email to detail what is being given today. There is a box of media, including VHS, cassette, and microcassettes, and newspaper articles that were provided by Reiter.

On the thumbdrive is a spreadsheet outlining what is included; items highlighted in blue are included. You will notice a comment "see disk tracking spreadsheet" in items not highlighted; this spreadsheet will be included in the disk copies we send over that will detail how many images total and how many removed.

There are loose disks which include 1B evidence scans, 1D1-1D5 evidence items, LSJ 3D imaging, and the FBI file.

Separately, we will keep you updated as we continue to work on the redactions and will let you know as soon as we finish with the disks.

Let us know you have any questions.

[
[Redacted] Sep 3, 2020 10:49 PM
To
[Redacted][Redacted] (NY) (FBI)[Redacted][Redacted][Redacted]
Cc
[Redacted][Redacted][Redacted] (USANYS)

Thanks again so much for getting these materials to us. I've got a few follow up questions on discovery issues below. Feel free to give me a call to talk through these if that's easier.

• Any update on the status of the scanning and disc reviews?

• Any update from CART on the paperwork?

• I'm a bit confused about some of the files on the thumb drive you provided:

  • o None of the audio files in the folder entitled "Grand Jury Testimony 7.19.06" are playing for me. Are you able to play them?

  • o In the folder entitled "Additional scans PBPD" and the folder entitled "Scans from reiter" — where did these documents come from?

  • o In the folder entitled "Items from Reiter — disks" — There are a bunch of subfolders that seem empty or to have files that have nothing to do with the Epstein investigation, or that won't open. Can you let me know where these came from and what they are?

[
[Redacted] (NY) (FBI) Sep 8, 2020 4:21 PM
To
[Redacted]
Cc
[Redacted][Redacted] (USANYS)

We are working on exporting and copying over the images to a drive today to get over to you. It's taking a while to transfer, but it is processing. When is someone in the office next that we can drop off to one of you?

Still working on CART.

We were not able to play the GJ audio files either. We tried a couple different programs. We can see if someone can attempt to recover it.

The scans all came from Reiter who said he took possession of them after passed...these were all turned over in hard copy form to us and scanned.

"Items from Reiter-disks"

• The ones that were empty are empty disks but were labeled as labeled in the folder

• All of these are from JE residence and were copies of PBPD property. Are there ones in particular that you noticed don't seem to be from JE investigation?

1419 files from the DOJ Epstein case media release. All files are public records from justice.gov.

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