From:

To:

Subject: Re: Discovery questions

Date: Wed, 19 Aug 2020 22:35:14 +0000

Great

Sent from my iPhone

On Aug 19, 2020, at 6:34 PM, <empty>) <<empty>> wrote:

Yep, it looks like we have all of the trash pulls—I think they did the organizational structure you asked for when they gave it to us back in September.

From: 
Sent: Wednesday, August 19, 2020 2:33 PM
To: 
Subject: FW: Discovery questions

For the scans, let me know if you're seeing things like trash pulls in the scans they sent you. It should be more than just phone message pads. If it's not in there, let's take up on the offer to request another copy from them.

Email Details:

*   **From:** (NY) (FBI)
*   **Sent:** Wednesday, August 19, 2020, 2:21 PM
*   **To:**
*   **Cc:** (USANYS)
*   **Subject:** RE: Discovery questions

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.

EFTA00030986

Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:

- Sender title: Special Agent, FBI New York Field Office — Child Exploitation/Human Trafficking
- From: [redacted]
- Sent: Tuesday, August 18, 2020 6:41 PM
- To: [redacted; multiple recipients]
- Cc: [redacted; multiple recipients — includes markers “(NY) (FBI)” and “(USANYS)”]
- Subject: [EXTERNAL EMAIL] - RE: Discovery questions
- Message snippet: "Thanks so much, 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."
- Note: Names and email addresses are redacted in the image.

Thanks so much, 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.

The image is an email header.

*   **From:** Blacked out
*   **Sent:** Tuesday, August 18, 2020, 6:40 PM
*   **To:** Blacked out
*   **Cc:** One recipient listed as (NY) (FBI), one listed as (USANYS). Other recipients blacked out.
*   **Subject:** Re: Discovery questions

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.

Key entities:

*   Detective
*   NYPD/FBI
*   Child Exploitation Human Trafficking Task Force
*   Office (redacted)
*   Cell (redacted)
*   Fax (redacted)

EFTA00030987

Key Details:

*   **From:** (Redacted)
*   **Sent:** Tuesday, August 18, 2020, 6:03 PM
*   **To:** (Redacted)
*   **Cc:** (Redacted) (NY) (FBI), (Redacted) (USANYS)
*   **Subject:** RE: Discovery questions

Hi and

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,

Key information from the email:

*   **From:** \[REDACTED]
*   **Sent:** Tuesday, August 18, 2020 4:41 PM
*   **To:** \[REDACTED]
*   **Cc:** \[REDACTED] (NY) (FBI), \[REDACTED], \[REDACTED] (USANYS)
*   **Subject:** RE: Discovery questions

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,

From: [REDACTED] <[REDACTED]>
Sent: Tuesday, August 18, 2020 4:45 AM
To: [REDACTED] <[REDACTED]>
Cc: [REDACTED]; [REDACTED] (NY) (FBI) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [additional redacted recipients]
Subject: RE: Discovery questions

Sorry, got a bounceback for too. I'm just attaching the one page I referenced in my email below. Hopefully that will go through.

Key information from the email header:

*   **From:** \[Redacted]
*   **Sent:** Tuesday, August 18, 2020, 4:40 AM
*   **To:** \[Redacted]
*   **Cc:** \[Redacted] (NY)(FBI), \[Redacted], \[Redacted] (USANYS)
*   **Subject:** FW: Discovery questions

EFTA00030988

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,

| Field | Text shown |
|---|---|
| Leading word | Thanks, |
| From | [redacted] |
| Sent | Tuesday, August 18, 2020 4:33 AM |
| To | [redacted] <[redacted]>; [redacted]. (NY) (FBI) <[redacted]> |
| Cc | [redacted] (USANYS) <[redacted]>; [redacted] <[redacted]> |
| Subject | Discovery questions |

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.

Thanks very much,



Assistant United States Attorney

EFTA00030989

Southern District ofNew York
1 St. Andrew's Plaza
New York,NY 10007
212-637-2324

EFTA00030990