EFTA00138663¶
| Fw: Statements by Mr. Tartaglione | |
| From | Michael Bachrach |
| To | Kenneth J. Montgomery Esq, Michael Bachrach, Michael BachrachTony Ricco |
| Date | 2019/11/19 14:22 |
| Subject: | Fw: Statements by Mr. Tartaglione |
| Attachments: | TEXT.htm,Mime.822 |
Bruce B. has brought the following exchange to my attention. Yes, to the extent the request has been made to you please consider it as a Rule 16 request as we view this information as discoverable as Rule 16 material as to the penalty phase.¶
Also, in light of your offer, we will hold off for now on pursuing the request with the MCC/BOP to avoid duplicative efforts. We appreciate your assistance, as your aid could certainly speed things along.¶
—Michael¶
| Michael K. Bachrach, Esq. |
| 276 Fifth Ave., Suite 501 |
| New York, NY 10001 |
| tel: (212) 929-0592 |
| fax: (866) 328-1630 |
| cell: (917) 304-5044 |
| BOP email to: |
| All other email to: |
| ----- Forwarded Message ----- |
| From: Bruce Barket |
| To: Michael Bachrach(michael@mbachlaw.com) |
| Sent: Tuesday, November 19, 2019, 07:38:07 AM EST |
| Subject: FW: Statements by Mr. Tartaglione |
Received this¶
Bruce A. Barket, Esq.¶
Barket Epstein Kearon Aldea & LoTurco, LLP¶
666 Old Country Road , Ste. 700¶
Garden City, NY 11530¶
(516) 745 1500 [P] (516) 745 1245 [F]¶
SDNY_00016754¶
Page 11230¶
EFTA00138664¶
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¶
Sent: Monday, November 18, 2019 5:37 PM¶
To: ; Bruce Barket;¶
Cc: Aida Leisenring¶
Subject: RE: Statements by Mr. Tartaglione¶
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.¶
Assistant United States Attorney¶
Cc: Aida Leisenring aleisenring@barketepstein.com¶
Subject: Re: Statements by Mr. Tartaglione¶
Hi Bruce,¶
Pursuant to FOIA/Privacy Act and Touhy regulations, we need a release from the inmate, Touhy letter, and subpoena for the request to be considered locally. Please also be advised that we would have to seek authority under Touhy through the USAO.¶
you,¶
¶Bruce Barket bharket@harketonstein.com 11/17/2019 5:03 PM >>
SDNY_00016755 Page 11231¶
Page 153¶
EFTA00138665¶
Bruce Darnell www.barnelepstein.com 11/17/2015 3:00 AM¶
It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July 22nd or the early hours of July 23, 2019 concerning Jeffrey Epstein’s reported attempted suicide attempt. Pease provide the record of any statements made by Mr. Tartaglione, any written statements made by Mr. Tartaglione and any recording of any such statements.¶
Bruce A. Barket, Esq.¶
Barket Epstein Kearon Aldea & LoTurco, LLP¶
666 Old Country Road , Ste. 700¶
Garden City, NY 11530¶
(516) 745 1500 [P] (516) 745 1245 [F]¶
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¶
SDNY_00016756 Page 11232¶
Page 154¶
EFTA00138666¶
Bruce B. has brought the following exchange to my attention. Yes, to the extent the request has been made to you please consider it as a Rule 16 request as we view this information as discoverable as Rule 16 material as to the penalty phase.¶
—Michael¶
Also, in light of your offer, we will hold off for now on pursuing the request with the MCC/BOP to avoid duplicative efforts. We appreciate your assistance, as your aid could certainly speed things along.¶
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 SDNY_00016757¶
Page 155¶
EFTA00138667¶
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.¶
Assistant United States Attorney¶
Hi Bruce,¶
Pursuant to FOIA/Privacy Act and Touhy regulations, we need a release from the inmate, Touhy letter, and subpoena for the request to be considered locally. Please also be advised that we would have to seek authority under Touhy through the USAO.¶
¶Bruce Barket
11/17/2019 5:03 PM >>>>
¶
It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July 22nd or the early hours of July 23, 2019 concerning Jeffrey Epstein’s reported attempted suicide attempt. Pease provide the record of any statements made by Mr. Tartaglione, any written statements made by Mr. Tartaglione and any recording of any such statements.¶
Bruce A. Barket, Esq.¶
Barket Epstein Kearon Aldea & LoTurco, LLP¶
666 Old Country Road , Ste. 700¶
Garden City, NY 11530¶
[516] 745 1500 [P] [516] 745 1245 [F]¶
SDNY_00016758¶
Page 156¶