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In the United States District Court for the District of Hawaii

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In the United States District Court for the District of Hawaii Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 1 of 17 PageID #: 5000 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII UNITED STATES OF AMERICA, ) CIVIL NO. 17-00101-LEK ) Plaintiff, ) DECLARATION OF ) SPENCER PAE vs. ) ) ANTHONY WILLIAMS, ) ) Defendant. ) ) ) I, SPENCER PAE, STATE THE FOLLOWING UNDER PENALTY OF PERJURY: 1. I am a Computer Services Manager employed by the Federal Bureau of Prisons (BOP), in the Federal Detention Center Honolulu, HI (FDC Honolulu). I have held this position since 2013. I started my BOP career at FDC Honolulu in 2002. 2. I am making this declaration in United States v. Williams, No. 17-00101-LEK. I understand inmate Anthony Williams, Reg. No. 05963-122, has represented to the Court he is unable to view his electronic discovery while housed at FDC Honolulu. Specially, he claims he is unable to view files on twenty one (21) discs furnished to him by the U.S. Attorney's Office containing discovery for his criminal case. 3. My duties as IT manager include maintenance and administration of all computer hardware, infrastructure, Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 2 of 17 PageID #: 5001 networks, and systems for FDC Honolulu staff and inmates. As relevant to this case, I maintain the e-discovery computers located in all inmate housing units and the attorney-client visitation rooms intended for inmate review of electronic discovery materials ("e-discovery PCs"). 4. The e-discovery PCs are standardized across all BOP institutions, as determined by BOP's Information Technology Planning and Development Branch. Therefore, the e­ discovery computers cannot be modified locally at FDC Honolulu to enable new software. 5. E-discovery PCs are able to open multiple file types in "read-only" format. These file types include al·l common document, audio, and video formats, as well as many more obscure formats. Attached as Attachment 1 is a true and correct copy of the various file types BOP e-discovery PCs can open. 6. Through BOP agency counsel, the U.S. Attorney's Office provided me on August 30, 2019 with a copy of the twenty one (21) discs inmate Williams claimed to have difficulty opening on the SB e-discovery PC ("Williams discovery discs"). 7. I tested each and every Williams discovery disc on an e­ discovery PC identical to the one in inmate Williams's housing unit. The U.S. Attorney's Office requested I Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 3 of 17 PageID #: 5002 confirm that all file types with ~ubstantive discovery files could open and be viewed on the e-discovery PC from the Williams discovery discs. These included: .avi, .css, .db, .doc, .docx, .eml, .gif, .html, .jpeg, .jpg, .mov, .mpg, .pdf,· .pptx, .rtf, .tif, .wmv, .wps, .xls, .xlsx, and .xml file types. 8. Two of the file types, .db and .css, are for purely technical files which are not deliberately created by any user. They store miscellaneous system data mostly related to display properties an~ produce nonsensical characters if opened in a text document. These files are typically hidden in a regular computer and users are not even aware of their presence. I was unable to view these files. Therefore, I disregarded all .db and .css files. 9. One disc contained a handful of .tif files, which are image files. However, these specific files were null and had file sizes of "0 bytes." 10. Of the discs provided to me, twelve (12) worked with no issues ("error-free discs"). All error-free disc files were visible on the e-discovery PC. Two (2) discs had only one file each which would not open. I requested the U.S. Attorney's Office provide me with copies of these two files so I could print hard copies for inmate Williams. Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 4 of 17 PageID #: 5003 11. The remaining seven (7) discs all contained a single large file split over six discs, and one disc with an index file. These files were labeled as WILLIAMS_ET_AL_070046 (1 of 7), WILLIAMS_ET_AL_070046 (2 of 7), WILLIAMS_ET_AL_070046 (3 of 7), etc. 12. WILLIAMS_ET_AL_070046 (1 of 7) contained an index document listing the contents of WILLIAMS_ET_AL_070046 (2 of 7) to WILLIAMS_ET_AL_070046 (7 of 7). It also contained several media files. The index document could not properly display on the e-discovery PC. Therefore, I printed a hard copy for inmate Williams. 13. All files types on WILLIAMS_ET_AL_070046 (2 of 7) to WILLIAMS_ET_AL_070046 (7 of 7), including videos, properly displayed on the e-discovery PCs. However, .doc, .docx, and .xml files did not properly display on these discs. 14. To ensure inmate Williams was provided with 100% of the discovery in accordance with the Court's deadline, I asked the U.S. Attorney's Office to produce in hard copy each and every .docx, .doc, and .xml file. I understand a representative of the U.S. Attorney's Office will be delivering these files to FDC Honolulu later today, September 5, 2019. 15. As described above, inmate Williams will have all discovery present on the twenty one disc set, either in digital or Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 5 of 17 PageID #: 5004 hard-copy form. In accordance with FDC Honolulu policy, inmate Williams will be permitted to keep the discs and hard copies in his possession. 16. Attached as Attachment 2 is a true and correct copy of guidance on e-discovery procedures promulgated by former FDC Honolulu Warden William W. Lothrop and distributed to the defense bar community on May 1, 2017. The Legal Mail Drop Box is where defense counsel may leave hard copy and e-discovery for their clients before or after a legal visit. See Att. 2. Based on my knowledge of the routine legal mail delivery process at FDC Honolulu, the box is checked daily and mail is delivered in the early morning the next business day after an item has been deposited. 17. On September 5, 2019, I placed discovery materials for inmate Williams in the d~op box in an envelope addressed personally to him. Specifically, I enclosed twenty one (21) discs provided to me by the U.S. Attorney's Office. 18. All e-discovery PCs in the housing units have had their USB ports physically disabled. External hard drives, thumb drives, and any other peripheral USB device cannot be connected to these machines. External hard drives and thumb drives are prohibited at FDC Honolulu. See Att. 2 at 1. 19. These USB ports were disabled, among other reasons, because Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 6 of 17 PageID #: 5005 contraband cell phones can be charged through the ports. Possession of a contraband cell phone is a federal crime. Cell phones are among the most dangerous contraband items in a prison and can be used to arrange escapes, contraband smuggling, and all kinds of criminal activity outside the facility. A contraband cell phone was used just last year by an FDC Honolulu inmate to engage in witness tampering and drug sales. 20. As part of my duties, I am also part of the approval process for any external hard drives brought into the facility, whether by staff or inmates. Per this Court's order, inmate Williams has been allowed to keep three hard drives in his personal possession. Even though the USB ports on the e-discovery PCs have been disabled, FDC Honolulu has taken the additional precaution of providing Williams with the USB cable which connect the drives to the e-discovery PC only when Williams makes a written request to view the drives. 21. Arrangements have been made for Williams to view the hard drives in one of the attorney-client visitation rooms at the FDC. The e-discovery PCs in the attorney-client visitation rooms have functional USB ports. The USB cable is kept at the officer's station in the visitation room and is furnished to Williams when he comes down to view the Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 7 of 17 PageID #: 5006 .· hard drives. f/5.//~ in Honolulu, HI SPENCER PAE Computer Services Manager Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 8 of 17 PageID #: 5007 ATTACHMENT 1 Case 1:17-cr-00101-LEK Document 575-1 Filed 09/05/19 Page 9 of 17 PageID #: 5008 ID. Common File Types and Review Applications A. File Types Listed in the BOP July 2014 Electronic Discovery RFI The following is taken from the July 7, 2014, BOP RFI for support services, hardware and software for inmate electronic discovery., httus://www.fbo.gov/index?s=opportunity&mode=form&id=fal f57 c38041 cf651 el297aeb33f295c&tab=core& cview=l The following introduction to the BOP RFI is a useful presentation of BOP thought and restrictions in this area. The Federal Bureau of Prisons (BOP), Information Technology Planning and Development Branch has created a Request for Information to seek information related to support services, hardware, and software for inmate electronic discovery (eDiscovery). The goal of this RFI is to obtain detailed information for a secure computing device which can be used by inmates to view discovery materials related to their criminal defense against federal prosecution or their civil litigation against a federal entity. The BOP seeks information on available solutions for an eDiscovery system that incorporates actual hardware, any necessary software to view litigation material, and support services for BOP IT staffto troubleshoot issues or seek repair of equipment.
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