Thanks Andy, we will review and get back to you early next week.¶
We have attached a proposed disclosure cover letter that is modeled on a letter sent by the Government in United States v. Madonna, 17 Cr. 89 (CS). We have also attached proposed redacted disclosures. As you and I discussed, we offer this as a means to ensure our client’s safety while permitting the Government to comply with what you believe are your disclosure obligations.¶
As an alternative, we are willing to apply under seal to Judge Tones for a Protective Order to preclude the disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your efforts, we have an obligation to make sure that our client is not harmed by the possible release of the fact that he met with your Office.¶
We understand that you have time constraints. Please let us know how you want to proceed so that we can file a motion before Judge Tones promptly if that is necessary.¶
Andy¶
Andrew G. Patel Attorney at Law¶
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| Original Messa | ||
|---|---|---|
| From: | [mailto: | |
| Sent: Friday, December 20, 2019 10:01 AM | ||
| To: Andrew Patel | ||
| Cc: Jill Shellow; Don Yannella; | ||
| Subject: RE: Epstein |
Andy,¶
Attached are unredacted and redacted copies of the notes. As discussed, we intend to produce redacted copies of the notes pursuant to the protective order, and produce Mr. name and your contact information to defense counsel on an AEO basis. The file name will be changed to the bates number so it will not include his name.¶
I’m also copying my co-counsel please include them on emails going forward. Finally, is aware that we are providing these notes to you.¶
Thanks, and please feel free to give us a call to discuss.¶
Please send us a copy of the disclosure that you are considering as to Mr. . Seeing the planned disclosure about our client will help us fashion a means of addressing the concerns we discussed last night. Many thanks, Andy¶
Andrew G. Patel Attorney at Law¶
Sent from my phone¶