From: Aida Leisenring aleisenring@barketepstein.com¶
| Cc: Bruce Barket<bbarket@barketepstein.com> |
| Subject: Follow Up on July 23 Incident Sensitive Disclosure Materials |
| Date: Mon, 16 Dec 2019 21:52:17 +0000 |
Hello .¶
Thank you for taking the time to let us review sensitive disclosure materials in your office on Friday. We appreciate it. I just wanted to memorialize a few follow-up questions we had.¶
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It is our understanding that there is video surveillance in the hallway in or near the tier that was preserved in reference to the July 23 incident. We would like to see a copy of it.
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It is our understanding that there may be photographs or a video recording of cell 124 that would have been taken shortly after the incident. If so, we would like to see them.
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If the orange rope was preserved, we would like to view it in person.
Jason, I understand that you were not aware of the availability of the above and that you would look into this additional discovery. I just wanted to memorialize our follow up inquiries for your records.¶
Lastly, if the items above are available, does your office take a position with respect to our request to view them? We just need to know so we can plan our next course of action.¶
See you in Court, and thank you again for your time.¶
Aida Ferrer Leisenring, Esq.¶
Barket, Epstein, Kearon, Aldea & LoTurco LLP¶
666 Old Country Road, Ste 700¶
Garden City, NY 11530¶
Please note that my emailed has changed to:¶
aleisenring@barketepstein.com¶
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EFTA00079363¶