EFTA01077304Set 9
2011-03-186p1,821w
York 10022
RE: Fortress VRF I, LLC, et al v. Jeepers, Inc.
Potential Bates Number Gaps
Dear Seth:
This letter is in response to your February 3, 2011 email ... note, many of the ranges identified in your February 3, 2011 email
are the bates numbers of CDs or Hard Drives, and the documents contained therein are on the
hard ... drive we produced to you (DBZCO_FTC0000001A). Some others are bates numbers
intentionally left blank.
We have been unable to ascertain the status of the following bates ranges, but will
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077304.pdf
EFTA01097606Set 9
2007-12-204p1,007w
Staff's May 29, 2007 subpoena, enclosed please find a hard drive Bates-
numbered DBZ 0036141. The hard drive contains e-mail messages sent to or from the following
individuals ... that have not been previously produced to the Staff:
Raymond Chan (Bates-numbered DBZCOPR-03227313 -
DBZCOPR-03230788);
Robert Flowers (Bates-numbered DBZCOPR-03230789 -
DBZCOPR-03232205);
Michael Gora (Bates-numbered DBZCOPR ... Peter Altenbach December 20, 2007
Page 2
Perry Gruss (Bates-numbered DBZCOPR-03232241 -
DBZCOPR-03238015, and DBZCO02609533 -
DBZCO02622477);
Dana Letendre (Bates-numbered DBZCOPR-03319562 -
DBZCOPR-03319990);
Dermot Murphy (Bates-numbered
https://www.justice.gov/epstein/files/DataSet%209/EFTA01097606.pdf
EFTA00811395Set 9
2018-11-2112p4,431w
instead turn over the CD2 with
responsive documents to Farmer Jaffe to duplicate and Bates number, to prepare a privilege log, and
to produce non-privileged documents to Mr. Epstein ... print a hard copy of all of
the documents contained on the discs with Bates numbers added,
and will provide a set of copied, stamped documents to the Special
Master ... Miami
office on December 8, 2010, and was responsible for the discs and the Bates numbering and printing
of the documents. (Fowler White Ex. C; Sanchez Decl
https://www.justice.gov/epstein/files/DataSet%209/EFTA00811395.pdf
EFTA00802116Set 9
2018-10-2612p4,437w
instead turn over the CD2 with
responsive documents to Farmer Jaffe to duplicate and Bates number, to prepare a privilege log, and
to produce non-privileged documents to Mr. Epstein ... print a hard copy of all of
the documents contained on the discs with Bates numbers added,
and will provide a set of copied, stamped documents to the Special
Master ... Miami
office on December 8, 2010, and was responsible for the discs and the Bates numbering and printing
of the documents. Declaration of Lilly Ann Sanchez
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802116.pdf
EFTA00808583Set 9
2018-07-267p1,054w
DEFENDANT JEFFREY EPSTEIN'S MOTION TO
COMPEL COUNTER-PLAINTIFF BRADLEY J. EDWARDS TO IDENTIFY BATES
NUMBERS OF DOCUMENTS PRODUCED
Bradley J Edwards ("Edwards"), by and through undersigned counsel, hereby files ... Response in Opposition to Defendant Jeffrey Epstein's Motion to Compel Edwards to Identify
Bates Numbers of Documents Produced thereto, and as grounds therefor states as follows:
In 2012, Edwards ... Case No. 502009CA040800XXXXMBAG
Response in Opposition to Epstein's Motion to Compel Identification of Bates Number.
relitigate waived discovery issues in order to continue wasting Court resources and to ensure
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808583.pdf
EFTA00802097Set 9
2018-10-267p1,935w
file folder on Fowler White's computer, and a
software program then placed consecutive Bates numbers on these documents ranging from 1
through ... that the Bates stamping process occurred on December 8, 2010, as the application of
Bates numbers constituted a "modification" to the CD. [32:14-21]. One hard copy of these ... documents was then printed with Bates numbers affixed. [69:16-21]. The hard copies were mailed
to Farmer Jaffe on December
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802097.pdf
EFTA01077310Set 9
2011-03-252p362w
York 10022
RE: Fortress VRF I LLC, et al. v. Jeepers, Inc.
Potential Bates Number Gaps
Dear Seth:
This letter references my March 18, 2011 letter under which we produced ... produced as DBZCO_FTC0000001A.
We have determined that DBZ 0035150 - DBZ 0035153 are the bates numbers of CDs
produced to the SEC, and the documents contained therein ... produced
to you (DBZCO_FTC0000001A). We have not been able to locate documents bates numbered
DBZ 0008634 - DBZ 0008855.
Please find enclosed a CD bates numbered DBZCO_FTC0022279, containing
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077310.pdf
EFTA00030926Set 8
2021-02-038p2,364w
paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was
recovered from one of Epstein ... from . As to your inquiry about the Bates ranges on the documents
beginning with Bates number "28', I note that the folder containing the subpoena returns in our August ... cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover
https://www.justice.gov/epstein/files/DataSet%208/EFTA00030926.pdf
EFTA00023026Set 8
2021-01-184p1,664w
paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was
recovered from one of Epstein ... your inquiry about the Bates ranges on the Rodgers documents
beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August ... cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023026.pdf
EFTA00011489Set 8
2021-01-295p2,002w
paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was
recovered from one of Epstein ... your inquiry about the Bates ranges on the Rodgers documents
beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August ... cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011489.pdf
EFTA00030912Set 8
2021-01-296p2,197w
paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was
recovered from one of Epstein ... your inquiry about the Bates ranges on the Rodgers documents
beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August ... cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover
https://www.justice.gov/epstein/files/DataSet%208/EFTA00030912.pdf
EFTA00020978Set 8
2021-02-015p2,302w
paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was recovered
from one of Epstein ... your inquiry about the Bates ranges on the Rodgers documents
beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August ... cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover
https://www.justice.gov/epstein/files/DataSet%208/EFTA00020978.pdf
EFTA00011259Set 8
2021-02-027p2,382w
paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was
recovered from one of Epstein ... your inquiry about the Bates ranges on the Rodgers documents
beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August ... cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011259.pdf
EFTA00015219Set 8
2020-05-2658p17,292w
These records are referred to in this declaration collectively as the
Bates-stamped or Bates-numbered records.' I On the pages released in full or in part, these
" In contrast ... subject to categorical withholding per Exemption 7(A). Thus, when I refer to the Bates-
numbered records, I am not including the records processed after July 2019 that were subject ... with Plaintiffs,
FBI discovered a number of documents that were stamped with previously-used Bates numbers.
As a result, the documents that were previously Bates-stamped 03956-10980 through
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015219.pdf
EFTA00099413Set 9
2020-06-053p764w
training.
11. The Inmate Accountability Institutional Supplement/Program Statement,
Number I.S. NYM 5511.08, referenced in bates number SDNY 0005392.
12.The Security Inspections Institutional Supplement/Program Statement,
Number I.S. NYM 5500.13, referenced ... bates number SDNY 0005392.
13.An unredacted copy of SDNY 7551.
14.An unredacted copy of SDNY 883.
15. SHU Watch Call Logs from August 9, 2019 and August 10, 2019.
16.All ... June 24, 2018.
30. Who is the author of the 4Chan message produced as bates number
SDNY_00006978?
31. All internal and external investigation records related to the suicide
https://www.justice.gov/epstein/files/DataSet%209/EFTA00099413.pdf