We are available Monday at 4 pm or any time on Wednesday. Let us know what works for the defense team.¶
Let’s set up a call as I believe that the material I requested is relevant and we are entitled to it.¶
Bruce A. Barket, Esq.¶
Barket Epstein Kearon Aldea & LoTurco, LLP¶
666 Old Country Road , Ste. 700¶
Garden City, NY 11530¶
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments¶
From: [USANYS] [mailto:]¶
Sent: Friday, November 22, 2019 11:51 AM¶
To: Bruce Barket; Aida Leisenring; Tony Ricco; BRUCE KOFFSKY;¶
Montgomery Esq¶
; John Diaz; Kenneth J.¶
Subject: RE: Statements by Mr. Tartaglione¶
All,¶
In response to your request for any statements made by Mr. Tartaglione during interviews at the MCC related to the investigation into an event involving Jeffrey Epstein on or about July 23, 2019, we are producing to you a zip folder with reports of those statements. The zip folder also contains reports of statements attributed to Mr. Tartaglione that were¶
EFTA00072699¶
conveyed to MCC staff by Mr. Epstein. These materials have been marked “sensitive” pursuant to the protective order in this case and should be treated accordingly.¶
In response to your additional request for “all the reports and video regarding Mr. Epstein’s attempted suicide on July 22-23rd,” we do not believe these materials are relevant to this case or covered under Rule 16, and therefore will not be producing them. If you would like to discuss further, please give us a call.¶
Thank you.¶
In addition to the statements attributed to Mr. Tartaglione we are asking did for all the reports and Video regarding Epstein’s attempted suicide on July 22-23rd.¶
I believe we sent a letter to the MCC shortly after the event asking that the video be preserved.¶
Bruce - To the extent your request is to the MCC/BOP, the request is governed by the procedures set forth below in email. To the extent the request is to our office pursuant to Rule 16, as a courtesy, we will look to see what statements are in our possession and gather and produce them to you by the end of the week. The production will be pursuant to the protective order in this case.¶
Hi Bruce,¶