November 26, 2021 VTC prep
AUSA
Del.
Prepared for trial. new/corrected/clarified statements below:
• clarified that she and SA completed the CD review in summer 2020, not
summer 2019.
• understands that the "created date" in metadata for the images from the CDs is the
date the file was copied onto FBI computer. understands that the "modified date" in
metadata for the images from the CDs is date the image file was originally created.
• In preparation for GM trial, reviewed all photos from all CDs seized from JE NY
residence and identified photos containing images of any relevant locations, victims, or
targets (including GM).
• will doublecheck the 1B number corresponding to all GX being offered through her
at trial. previously created chart outlining corresponding 1B numbers and other
information, including CD title for the GX being offered through her at trial:
o GX-304
o GX-306
o GX-307
o GX-309
o GX-313
o GX-314
o GX-317
o GX-318
o GX-320
o GX-321
o GX-322
o GX-324
o GX-325
o GX-332
o GX-333
o GX-337
o GX-340
o GX-341
o GX-347
o GX-348
3531-006
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00010137
EFTA00159786