EFTA00020430
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Inline-Images: image001jpg; image002.jpg Thanks, Please send the dots via the link below:
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 for data showing when a particular file was saved to a drive by the investigative team or prepared for production.
5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY_GM_00467566 though SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so they did not come from any of the electronic devices that were the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I have asked our vendor to look into this issue and will get back to you when I have spoken with them.
6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I note again that 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. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the SDNY011 load file (Bates range SDNY_GM_00467566 though SDNY_GM_00514100) were seized during the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so they did not come from any of the electronic devices that were the subject of extractions by CART. As a result, these images would not have CART numbers.
7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to them. Best, Assistant United States Attorney
Southern District of New York
These fall into the following buckets: a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have "date created" and "date last modified" dates in September-November 2020, after the date the device was seized. We request that you produce a metadata overlay with the original metadata for these files. b. SDNY005 (October 20 2020 production): these are a few videos from the SDFL or PBPD investigations that were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that you produce a metadata overlay with the original metadata for these files. c. SDNY011 (November 9 2020 production): these were produced in native form with load files, but do not reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these files or indicate their source. Also, we request that you produce a metadata overlay with the original metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that intentional or are we missing those documents? Please let us know your responses as soon as possible. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP Eltil l I view bio www.cohengresser.com New York I Pans I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed at httpslAvww.cohengressercom/privacy-policx
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Type
Foia ReleaseSource
DOJ - Data Set 8Release Date
January 24, 2025
Pages
4
File Size
234.5 KB
Format
Data Set
data-set-8
OCR Confidence
ID: EFTA00020430
Last updated: Apr 7, 2026
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