Proposed email:¶
Good morning Bruce,¶
I wanted to lay out the access to digital discovery currently available to Mr. Tartaglione and my intention of following up with the staff who oversee those areas to ensure he is getting to review the material.¶
As discussed, inmates can have CD/DVD-Roms on their housing units to review on the discovery computers located therein. All other digital media is limited to review in the Education Department and Attorney Conference.¶
Mr. Tartaglione’s regular unit library day is Wednesday from around noon until 3 pm. Inmates who need more digital discovery review time for non-disk media can request the time by writing to the Education Department. In Mr. Tartaglione’s case, I asked Education staff to call him down and arrange a schedule for him to review discovery there Monday through Thursday. As discussed previously, he declined to review the material at the time they spoke. I will ask them to revisit the offer for him to review discovery in Education from 8 am until 3 pm, Monday through Thursday.¶
Mr. Tartaglione cannot review discovery in Education on Fridays as that time is dedicated for the female population to access the library, medical and mental health services, and other programs. Instead, I have arranged for him to review his discovery in the attorney conference room area Friday evenings between 5 pm and 8 pm, and Saturday and Sunday between 8 am and 3 pm.¶
Mr. Tartaglione can also have more disks sent in to him by your office, office, and/or the USAO to review on the housing unit during times when access to the Education Department and/or the attorney conference room area are unavailable. Between all these available methods of discovery review, Mr. Targaglione is afforded more time than any other inmate in the facility and the maximum amount of access currently available consistent with institutional safety and security concerns. Please encourage him to utilize the time provided and to notify a lieutenant or unit team staff if he is having any difficulty getting to either Education or attorney conference. If you wish to discuss this matter further please let me know.¶
EFTA00104902¶
I can do 9 if that works. I have a teleconference at 11, a meeting at 1, and have to leave by 3 tomorrow.¶
Sent from my Verizon, Samsung Galaxy smartphone¶
I have a court conference right at 10. Any chance you could do a bit earlier or a bit later in the morning?¶
Thanks,¶
EFTA00104903¶
Can we chat at 10?¶
Sent from my Verizon, Samsung Galaxy smartphone¶
Very sorry to bother you, but would you be available for a call tomorrow to discuss? We need to make sure Tartaglione has regular access to his discovery.¶
Assistant United States Attorney¶
Southern District of New York¶
1 St. Andrew’s Plaza¶
New York, NY 10007¶