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Case 3:14-cr-00293-M-BK Document 258-5 Filed 05/19/16 Page 1 of 5 PageID 3523

PRODUCTION NUMBER DATE OF AUSA’s LETTER DESCRIPTION GIGABYTES (GB)

DATE PRODUCTION BECAME
AVAILABLE TO DEFENSE
COUNSEL VIA SUMMATION

September 9, 2014  10 discs of materials
01 *FPD seized by search 24.4 GBs
Summation November 16, 2015 warrant
• 276 discs of
Commissioners Court (CC)
proceedings

File format of 276 discs was
subsequently changed

02 September 19, 2014 Letter regarding
ancillary issues
03 November 25, 2014 • Materials seized by 493 GB
search warrant; “GE” (renumbered to GDP #4)
stamp = 1B materials
likely to be used in  7 Hard Drives
Gov.’s case in chief (renumbered to GDP #6)
• Pole camera videos

Correction Letter 03 December 18, 2014 20 DVDs CC recordings 94 GBs
(previously 276 discs)
Estimated using rate
of 4.7GBper DVD

03(a) February 6, 2015 10 CDs of CC recordings 7 GBs
not previously produced
Estimated

04 *FPD December 18, 2014 • Materials seized by 458 GBs
Summation search warrant; “GE”
Majority of Production became stamp = 1B materials
Production still has available on February 3, 2016 likely to be used in
unresolved issues Uploading completed on April 5, Gov.’s case in chief
2016
04(a) *FPD September 16, 2015 Additional materials 3.8 GB
Summation obtained by search
November 16, 2015 warrant and e-info
by 18 U.S.C.
2703(d) order

5.1 *FPD February 6, 2015 Subpoenaed materials 370 GBs
Summation with “SBP” stamp +
Majority became available on index
Production still has Summation on February 3, 2016
unresolved issues
Government subsequently
produced additional files and
FPD finished processing on
April 1, 2016
5.2Case 3:14-cr-00293-M-BK
*FPD Document 258-5
May 15, • SubpoenaedPage 2 of 5 PageID 3524
2015 Filed 05/19/16
Summation materials with SBP &  370 GBs
Majority became available on Bates #s + index
-------------------------- Summation on February 3, 2016 -------------------------- --------------------------
but still incomplete as
Provided to Defendants of March 15, 2016 • CC videos &  70.8 GBs
miscellaneous Audios
FPD has finished processing
as of April 1, 2016

5.3 *FPD July 31, 2015 • Emails and documents
Summation provided by Dallas 536.6 GBs
First became available via County
Major issues with Metadata still Summation on November 25, (1.3 million files)
remain but Government has 2015 but wasn’t workable. • SBP-1A-560
represented that Defendants • SBP-1A-562
have what Government has FPD still reviewing solutions
as of February 3, 2016

Government subsequently
produced additional files and
FPD finished processing on
April 1, 2016.

5.3 Supplement September 16, 2015 Revised index
5.4 *FPD November 17, 2015 Two discs; One disc
Summation contains additional .08 GBs
November 25, 2015 documents from
Business U in
Concordance. The
other disc contains
QuickBooks material

5.5 *FPD January 28, 2016 Additional subpoenaed 7 GB
Summation material - Business V
March 14, 2016
contains
5.6 *FPD February 26, 2016 Additional .065 GB
Summation subpoenaed material
March 14, 2016

5.7 *FPD March 31, 2016 Additional subpoenaed
material. More .11 GBs
April 11, 2016 (on disc) specifically, this is a
second batch of
materials for SBP-1A-
170 that were
subpoenaed

5.8 *FPD May 4, 2016 Additional subpoenaed .116 GBs
Summation material.

--------------------------
Pending

Provided to Defendants
– Correction
06Case 3:14-cr-00293-M-BK
letter Document 258-5
December 18, 2014Filed 05/19/16
Pole camera Page
videos 3 of 5 3,533
PageIDGBS 3525
7 HARDDRIVES
POLE CAM # 1
• 269 GB
• 462 GB (1D3)
• 923 GB (1D6)
• 507 GB (1D9)

POLE CAM # 2
• 295 GB (1D5)
• 928 GB (1D7)
• 149 GB (1D10)

07 *FPD June 25, 2015 • Subpoenaed materials 1.12 GBs
Summation (“1C” bates stamped)
February 3, 2016 • Materials acquired by Government
originally estimated
other means the size as 9.31 GBs.
The files originally produced (“Main 1A”) + Index On November 17,
by the Government were not 2015, the Government
useable by the FPD’s Office. sent a letter stating
the actual capacity
Production was reprocessed was 1.12 GBs.

07(a) *FPD September 16, 2015 Additional “Main 1A” .11 GB
Summation materials
November 19, 2015

7(b) *FPD January 28, 2016 Additional “Main-1A” 3.9 GB
Summation material
March 14, 2016

08 *FPD March 26, 2015 Outline of 4 Terabytes of 2300 GBs
Summation “digital evidence” from (2.3 TBs)
electronic devices and in
Not yet available on
the possession of North
Summation and substantially Texas Regional Computer Materials not
more devices need to be Forensics Lab (RCFL) produced with the
processed letter but were
subsequently
Processing began on produced to FPD to
January 26, 2016 be processed and
hosted on
64 of approximately 182 Summation
devices have been processed
as of May 16, 2016

8(a) *FPD May 4, 2016 Photographs of the 3.43 GBs
Summation electronic devices
outlined in the North
Pending
-------------------------- Texas Regional
Computer Forensics Lab
(RCFL) digital evidence
Provided to Defendants
spreadsheet and reports
regarding those devices.

Updated Spreadsheet June 25, 2015
Updated Notice of Data Imaged October 12, 2015
Updated Spreadsheet December 9, 2015
Updated Spreadsheet February 5, 2016
Case 3:14-cr-00293-M-BK Document 258-5 Filed 05/19/16 Page 4 of 5 PageID 3526
February 19, 2016 Roughly 2.3 TBs of 2.3 TBs
Production #8 was provided to --------------------- material from all
Defendants on a 3TB Hard-drive Defendants are also independently electronic storage Duplicative
processing this material. Defendants
began processing the material on
devices seized and
February 20, 2016. To date, 38 devices processed by the
of approximately 182 total devices have RCFL
been processed.

09 June 25, 2015 Notice of 14 Banker’s 16.8 GBs
Boxes of documents
obtained by a “citizen” Estimated using rate of
who bid on a storage 1.2 GBs per Banker’s
unit in default Box in acccordance with
GDP#19 after scanning

10 *FPD August 11, 2015 Privilege logs from 1.1 GBs
Summation Dallas County,
November 16, 2015 various businesses Logs were not
produced with letter
and individuals but were subsequently
produced 9/29/15
from FPD on disc

11 August 11, 2015 “1-D” recordings & 29 GBs
data
12 July 1, 2015 Search warrant photos 1.9 GBs

13 *FPD September 22, 2015 Unredacted copies of 1.1 GBs
Summation September 23, 2015 the sealed search
warrant applications,
search warrants, search
November 16, 2015 warrant returns, as well
as materials related to
the execution of the
search warrants and
other materials in 16
Cause Numbers

14 July 31, 2015 Bulky materials & Unknown
valuables + Index

Revised Index September 16, 2015

15 July 31, 2015 Surveillance photos 11.3 GBs
16 *FPD August 11, 2015 Consists of additional .66 GBs
Summation statements of
November 16, 2015 Defendants, legal
representatives and
media materials

16(a) *FPD May 4, 2016 Consists of FBI .027 GBs
Summation Special Agent notes
Pending regarding an
-------------------------- interview of Dapheny
Fain on June 27,
Provided to Defendants 2011.
17Case 3:14-cr-00293-M-BK Document
August 258-5
27, 2015 Filed 05/19/16
Consists of 4Page
discs 5 of 5 2.8
PageID
GBs 3527
of materials from
civil forfeiture cases Estimated

18 *FPD August 11, 2015 Consists of IRS tax .39 GBs
Summation returns and audits (per FPD)
UPDATED
Replaced by 18(a)
on November 17, 2015
18(a) November 17, 2015 Consists of certified .24 GBs
IRS tax returns and (capacity of files on disc)
November 19, 2015 (on disc) audits related to this
case that replaces
Government’s
Production – 18

19 *FPD August 11, 2015 Notice of 9 Banker’s 10.8 GBs
Summation Boxes of “filtered
UPDATED documents” provided
September 16, 2015 by former Dallas
County Clerk
November 16, 2015
UPDATE
9 Banker’s Boxes scanned

19(a) *FPD January 28, 2016 Consists of material .62 GBs
Summation that the Dallas County
March 14, 2016 District Attorney’s
Office removed from
Production 19 as
potentially privileged
material
20 August 11, 2015 Criminal Records -----
21 February 11, 2016 Christian Campbell’s .03 GBs
plea paperwork, prior
proffer agreement, re-
February 16, 2016 (on disc) arraignment transcript,
and his current 302s

*SOME MATERIAL IN
THIS PRODUCTION IS
UNDER SEAL

22 February 23, 2016 Consisting of pen .02 GBs
register applications
and court orders
March 1, 2016 (on disc)
*MATERIALS
UNDER SEAL

23 March 31, 2016 Consists of defense
Unknown exhibits and reciprocal .002 GBs
April 11, 2016 (on disc) discovery related to the
Business B [that was]
provided to the
government in the case
of United States v.
Helena Tantillo, No.
1:15-CR-0162-SS.
24 *FPD May 4, 2016 KM’s plea paperwork, .0023 GBs
Summation plea supplement and
Pending prior proffer agreement.
--------------------------
Provided to Defendants

TOTAL VOLUME PRODUCED 7, 970 GBS OR 7.9 TERABYTES