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efta-efta00138613DOJ Data Set 9Other

Re: Suicide Watch/Psych Observation Update

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DOJ Data Set 9
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EFTA 00138613
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118
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13
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Re: Suicide Watch/Psych Observation Update From To Date 2019/07/27 09:55 Subject: Re: Suicide Watch/Psych Observation Update Attachments: TEXT.htm Will.. » > > 7/27/2019 9A8 AM > » Thank you. When you assess him tomorrow, please let me know his status. Sent from my Verizon, Samsung Galaxy smartphone Ori inal message From: <■ Date: 7/27/19 9:46 AM (GMT-05:00) To: Subject: Re: Suicide Watch/Psych Observation Update > » " 07/27/201909:46 > » AW I saw him before his Legal visit. He seems stable and is now at his Legal visit. I'll be coming in tomorrow before his Legal visit to see him again. He complained about being dehydrated because he stated he cannot drink enough water because of limited bathroom breaks in Legal since he stated he sees his Attorney for about 12 hours. He also complained about having to go back up to SHU. Being anxious about it and not being able to sleep there because of the noise of inmates banging and screaming at night. >> > Good mornin

Persons Referenced (13)

The Warden

...ing on with the Epstein suicide investigation, but I suspect that is something the Warden cannot discuss. See you Wednesday. Hon. Valerie Caproni United States Distri...

Chief Psychologist

...xt door when he returns from legal as the toilet still does not work. Psy.D. Chief Psychologist U.S. Department of Justice/ Federal Bureau of Prisons Metropolitan Correctio...

Michael Greco

...Berman e Colleen McMahon District Executive Supervisory Staff Attorney MCC Michael Greco, U.S. Marshal Assistant United States Attorney Martin Weinberg, Counsel for M...

United States

...something the Warden cannot discuss. See you Wednesday. Hon. Valerie Caproni United States District Judge Southern District of New York 40 Foley Square New York, NY 10...

Case Management Coordinator

...on what happened with Epstein. Please review and see if he can be housed here. Case Management Coordinator MDC Brooklyn P.O. Box 329001 Brooklyn, New York 11232 I ext.5020 (718) 84...

United States Attorney

...ns Attachments: TEXT.htm, Mime.822 Thanks very much. Talk at 2pm. Assistant United States Attorney Southern District of New York New Yorb NY 10007 From: Bruce Barket < Sent:...

Associate Warden

...to on July 24, 2019, who passed on the information to her superiors. Thanks. Associate Warden MCC New York 150 Park Row New York, New York 10007 Office: 646-836-6452 Bl...

Martin Weinberg

...ff Attorney MCC Michael Greco, U.S. Marshal Assistant United States Attorney Martin Weinberg, Counsel for Mr. Epstein SDNY_00016768 Page 106 EFTA00138678 Re: Federal pri...

Jeffrey Epstein

...911:33 AM > » Hi DAD There has been an incident with a high profile prisoner (Jeffrey Epstein) at MCC New York. We are trying to get some basic information about the incide...

Supervisory Staff Attorney

...k pain medication. Please see him for these and other complaints. Thank you, Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New Yo...

Colleen McMahon

...the BOP concluded about that incident. p}', k ICJ II I Richard M. Berman e Colleen McMahon District Executive Supervisory Staff Attorney MCC Michael Greco, U.S. Marsha...

Staff Attorney

...ation. Please see him for these and other complaints. Thank you, Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New Yo...

Executive Staff

...665 SDNY_00016706 Page 10836 EFTA00138616 Fwd: Re: New Wrden From To NYM/Executive Staff] Date 2019/11/01 10:07 Subject: Fwd: Re: New Wrden Attachments: TEXT.htm...

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Re: Suicide Watch/Psych Observation Update From To Date 2019/07/27 09:55 Subject: Re: Suicide Watch/Psych Observation Update Attachments: TEXT.htm Will.. » > > 7/27/2019 9A8 AM > » Thank you. When you assess him tomorrow, please let me know his status. Sent from my Verizon, Samsung Galaxy smartphone Ori inal message From: <■ Date: 7/27/19 9:46 AM (GMT-05:00) To: Subject: Re: Suicide Watch/Psych Observation Update > » " 07/27/201909:46 > » AW I saw him before his Legal visit. He seems stable and is now at his Legal visit. I'll be coming in tomorrow before his Legal visit to see him again. He complained about being dehydrated because he stated he cannot drink enough water because of limited bathroom breaks in Legal since he stated he sees his Attorney for about 12 hours. He also complained about having to go back up to SHU. Being anxious about it and not being able to sleep there because of the noise of inmates banging and screaming at night. >> > Good morning, You assessed inmate Epstein today? Sent from my Verizon, Samsung Galaxy smartphone Original message > 7/27/2019 9:41 AM > » From: I-12th. 7 /17 MCI aiut AKA trarr_nc•nm SONY_00016703 Page 10828 Pape 101 EFTA00138613 MM. %VIVI I Subject: Suicide Watch/Psych Observation Update > » 07/27/2019 06:08 > > > Suicide Watch None Psych Observation 1. Epstein #76318-054 Thank you, SONY_00016704 Page 10829 Pace 102 EFTA00138614 Fwd: Suicide Watch/Psych Observation Update From To Lenin° NeDiaye Date 2019/07/27 09:49 Subject: Fwd: Suicide Watch/Psych Observation Update Attachments: TEXT.htm -FYI- Sad from my Writort Saimung Galaxy srmnphone ---1111,ncssa --- Front Date rrit To: Subject: Re: Suicide Watch/Psych Observation Update >»Mit 07/27/2019 09:46 >>> AW saw him before his Legal visit. He seems stable and is now at his Legal visit. I'll be coming in tomorrow before his Legal visit to see him again. He complained about being dehydrated because he stated he cannot drink enough water because of limited bathroom breaks in Legal since he stated he 9 He also complained about having to go back up to SHU. Being anxious about it and not being able to sleep there because of the noise of inmates banging Good morning, You assessed inmate Epstein today? Sent from my Verinan, Sant;ung Galaxy sinanphone From: Dat : 7/27/19608 AN To: Subject: Suicide Watch/Psych Observation Update >»1==" 07/27/2019 06:08 >» Suicide Watch None Psych Observation I. Epstein 476318.054 Thank you. 7/27/20199:41 AM >» SONY_00016/05 Page 10833 EFTA00138615 EPSTEIN, Jeffrey, reg. no. 76318-054 From To Date 2019/07/30 07:48 Subject: EPSTEIN, Jeffrey, reg. no. 76318-054 Attachments: TEXT.htm Good morning all, The above inmate's attorneys have recently alleged he is not receiving cholesterol or back pain medication. Please see him for these and other complaints. Thank you, Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 p• - t(646)836-7665 SDNY_00016706 Page 10836 EFTA00138616 Fwd: Re: New Wrden From To NYM/Executive Staff] Date 2019/11/01 10:07 Subject: Fwd: Re: New Wrden Attachments: TEXT.htm Another potential question for Wednesdi•elieve we are still usin staff and, if we have none who speak a particular language, a language line. Dr. and Commander can confirm. >> > < > 11/1/20199:51 AM >>> One other thing that you may be able to address (although this is more minor than the other issues): how does the prison deal with prisoners who rot speak English when they need to see a doctor? There is some interest in hearing what is going on with the Epstein suicide investigation, but I suspect that is something the Warden cannot discuss. See you Wednesday. Hon. Valerie Caproni United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 From: To: Date: 11/01/2019 07:56 PM Subject: Re: New Wrden Good morning Your Honor, My apologies, but I was out of the office unexpectedly yesterday due to a family emergency. Warden Petrucci and I will be in attendance at the CJAB next week. He indicates he will be addressing the issues that have delayed the attorney visiting study, to include those related to the union. He will also update the Court on the female unit at MCC. Please let us know if you need anything else. SDNY_00016707 Page 10840 Page 105 EFTA00138617 Thank you, Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 p• f. (646)836-7665 >> > < > 10/31/2019 10:39 AM >> > Will you- new warden be able to attend the CJAB meeting next week? Will you be attending? If so, would you like to give a brief explanation of the union issues associated with the attorney waiting times study? Hon. Valerie Caproni United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 SDNY_0001 6708 Page 10841 Page 106 EFTA00138618 Re: Draft language From To Date 2019/08/12 06:27 Subject: Re: Draft language Attachments: TEXT.htm can help if needed too. Soil from my Voizon. Samsung Galaxy mortphonc From: Dat • 8/ 1/19 6111 AM GMT-0 •00 To: < > Subject: Re: Draft language 08/12/201906:01 >>> Will Sem from my Vttizon. Samsung Galaxy smoriphunc O11 "nal messa -- From: Date: 8/12/19 5:31 AM GMT-05:00 To: Subject: Fwd: Draft language 08/12/2019 05:31 >>> In addition to details on those two staff, please pull total staffing info, number vacancies, AWOL, long term leave. etc. Also, status of curr Sou from my %tot ton. Sam ung Galaxy mnortphoro: messa From: Date: 8/11/19 11:12 PM GMT-05:00 To: Cc: Subject: RE: Draft language (CAGY' 08/11/2019 23:12 >>> Thanks. This is helpful. We can talk tomorrow about the timing. It will also be helpful to get some information about staffing at MCC I've seen additional press reports trying to link the staffing shortages. overtime and Thanks. From: To: Cc: tat II, 20 Sen • Subject: Draft language as discussed, several options arc below. Please note that we should discuss timing of all this. 1 will need to ensure staff are notified first, and I shout Preferred: Today<calendarT5:Today>, the Bureau of Prisons placed two staff who work in MCC NY on administrative leave pending the outcome of the investigat A more detailed version of above could read: Today<calendanT5:Today>, the Bureau of Prisons placed on administrative leave the two staff who worked in the Special Housing Unit at MCC NY pen SDNY_00016709 Page 10853 EFTA00138619 It a ultra stall member is aaaea enner version can tie changed to reaa - tture. If the warden is added, the following is proposed: The Bureau of Prisons also temporarily reassigned the MCC NY Warden to the Northeast Regional Office pending the outcome of the investigation. FCI While I prefer not to slate the wardcn's name in this release, if you decide it needs to be added, his name is Sent from my Verizon. Samsung Galaxy smartphone SONY_00016/10 Page 10854 EFTA00138620 Fwd: MEDIA REQUEST: Epstein & conditions at MCC From NYM/Exec Assistant— To Date 2019/08/13 12:21 Subject: Fwd: MEDIA REQUEST: Epstein & conditions at MCC Attachments: TEXT.htm Mike, This is concerning as this media venue is the one that has been relentless with BRO and MCC in the past. >> > Aviva Stahl < Hi there, > 8/13/201912:05 PM >>> writing a piece for the site Gothamist about conditions at MCC. See allegations below, compiled from defense attorneys, current prisoners and their loved ones. Please send comment ASAP if you would like to respond. Regards Aviva Stahl — that some cells in the facility are covered in mold — that some cells in the facility have separate spouts for hot and cold water, making it impossible for prisoners to take showers at a reasonable temperature — that prisoners at MCC are treated with disdain. They "be lucky if they were treated like dirt under somebody else's shoe, but they're not even treated that well," said one lawyer — that overcrowding, understaffing and underresourcing are grave problems at the facility ("whether its people who are suicidal, people who need medical care, people who need psychiatric care, people who need spiritual guidance or religious accommodation, people who need programming, so they don't just get warehoused there - all of that is lacking.") — that in the spring of 2019, toilets on the women's floor at MCC flooded, and the women were forced to clean up the feces themselves Follow me on Twitter @stahlidarity. Check out my writing portfolio at stahlidarity come and/or get regular updates from me about my work by signing up here. SDNY_00016711 Page 10857 EFTA00138621 Fwd: Draft language From To Date 2019 OS 1205:31 Subject: fwd. Draft langumy Attachments: II>: Limn In addition to details on those two staff. please pull total staffing info, number vacancies. AWOL, long term leave. etc. Also, status of curr Scm from my licrizon. Samsung Galaxy srmnplIon: Orivinal message From: Dat • tU 1119 11:12 PM MT-05:00 To: Cc: Subject: RE: Draft language >>> (OAG)' 08/11/2019 23:12 >» Thanks. This is helpful. We can talk tomorrow about the timing. It will also be helpful to get some information about staffing at MCC I've seen additional press reports hying to link the staffing shortages, overtime and Thanks, From: &mit\ ot 11,20 99: PM To: OAG Cc: Subject: Draft language as discussed. several options arc below. Please note that we should discuss timing of all this. I will need to ensure staff are notified first. and I shout Preferred: Today<calendanT5:Today>, the Bureau of Prisons placed two staff who work in MCC NY on administrative leave pending the outcome of the investigat A more detailed version of above could read: Today<calendar.T5:Today>, the Bureau of Prisons placed on administrative leave the two staff who worked in the Special Housing Unit at MCC NY pen If a third staff member is added either version can be changed to read "three." If the warden is added, the following is proposed: The Bureau of Prisons also temporarily reassigned the MCC NY Warden to the Northeast Regional Office pending the outcome of the investigation. FC1 While I prefer not to state the warden's name in this release, if you decide it needs to be added. his name is Sent from my Verizon. Samsung Galaxy snsanphone SDNY_00016712 Page 11005 Pane 110 EFTA00138622 Hello, I am here and will be able to provide any information you need. Warden N'Diaye is on annual leave this week and I am acting on his behalf. I did provide all the information that we have to on July 24, 2019, who passed on the information to her superiors. Thanks. Associate Warden MCC New York 150 Park Row New York, New York 10007 Office: 646-836-6452 Black Berry: > » 7/25/201912:25 PM » > Hi I contacted Associate Warden who is cc'd on this email, and she will be able to provide any information that you need. If you need anything else, please let me know. H. MM, Jr. Acting SDAD/CPD Federal Bureau of Prisons 320 1st St. NW, HOLC Bldg. 545 Washin ton, DC 20534 Office: > » ' (USMS)" < > 7/25/201911:33 AM > » Hi DAD There has been an incident with a high profile prisoner (Jeffrey Epstein) at MCC New York. We are trying to get some basic information about the incident and are having a hard time getting any information out of the facility. Is there someone we could speak to and get the basic information? The USM and Chief for our S/New York office are having no luck with the Warden and Assistant Warden. SDNY_00016713 Page 11009 PaQe EFTA00138623 Re: Inmate Epstein #76318-054 (Psych Observation) From To Date 2019/07/29 09:43 Subject: Re: Inmate Epstein #76318-054 (Psych Observation) Attachments: TEXT.htin He was still left in the same cell with a broken toilet. Please move him to the cell next door when he returns from legal as the toilet still does not work. Psy.D. Chief Psychologist U.S. Department of Justice/ Federal Bureau of Prisons Metropolitan Correctional Center 150 Park Row New York, New York 10007 Office: Fax: (646) 836-7712 E-mail: ).» 7/28/2019 9:43 AM > » The toilet may not be correctly working in cell #4 in the Psych Observation area. When he returns from Attorney Conference, please move him into a different cell. Thank you, SONY_00016714 Page 11040 Page 112 EFTA00138624 Re: Fwd: I/M Epstein #76318-054 From Date 2019/07/24 07:54 Subject: Re: Fwd: 1/M Epstein #76318-054 Attachments: TEXT.htin send it to her Psy.D. Chief Psychologist U.S. Department of Justice/ Federal Bureau of Prisons Metropolitan Correctional Center 150 Park Row New York, New York 10007 Office: Fax: (646) 836-7712 E-mail: > » 7/24/2019 7:51 AM > » Will take care of this? Since she saw him for the SRA yesterday, closest to the incident? Seems more relevant for her than I.■ you agree? >> > 7/24/2019 7:37 AM >> > Psy.D. Chief Psychologist U.S. Department of Justice/ Federal Bureau of Prisons Metropolitan Correctional Center 150 Park Row New York, New York 10007 Office: Fax: (646) 836-7712 E-mail: SONY_00016715 Page 11046 Page 113 EFTA00138625 Fwd: UM Epstein #76318-054 From Date 2019/07/24 07:37 Subject: Fwd: 1/M Epstein #76318-054 Attachments: TEXT.htm, I/M Epstein #76318-054 Psy.D. Chief Psychologist U.S. Department of Justice/ Federal Bureau of Prisons Metropolitan Correctional Center 150 Park Row New York, New York 10007 Office: Fax: (646) 836-7712 E-mail: SDNY_00016716 Page 11050 Pace 114 EFTA00138626 IINI Epstein #76318-054 From To Date 2019/07/23 22:17 Subject: 1/M Epstein #76318-054 Attachments: TEXT.htm The purpose of this email is to inquire as to whether or not inmate Epstein, Jeffrey #76318-054 is mentally capable of proceeding with the disciplinary process. Thanks in advance. SONY_00016717 Page 11054 Pace 115 EFTA00138627 Fwd: Inmate Epstein #76318-054 (Suicide Watch) From To Date 2019/07/23 10:56 Subject: Fwd: Inmate Epstein #76318-054 (Suicide Watch) Attachments: TEXT.htm, Inmate Epstein #76318-054 (Suicide Watch) Here you go.... sorry, I was in the middle of a crazy task! Psy.D. Chief Psychologist U.S. Department of Justice/ Federal Bureau of Prisons Metropolitan Correctional Center 150 Park Row New York New York 10007 Office: Fax (646) 836-7712 E-mail: SDNY_00016718 Page 11058 Paw 116 EFTA00138628 Inmate Epstein #76318-054 (Suicide Watch) From To Date 2019/07/23 08:56 Subject: Inmate Epstein #76318-054 (Suicide Watch) Attachments: TEXT.htm The Inmate Companion called and said that inmate Epstein wants to call his Attorney. SONY_00016719 Page 11062 EFTA00138629 RE: MCC conditions From Date 2019/08/30 13:49 Subject: RE: MCC conditions Attachments: TEXT.htm, Mime.822 Thanks very much. Talk at 2pm. Assistant United States Attorney Southern District of New York New Yorb NY 10007 From: Bruce Barket < Sent: Friday, August 30, 2019 1:47 PM To: Cc: ricco >; MichaelBachrach ( Subject: Re: MCC conditions 1-800-977-8002 Participants Code - Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 1:26 PM, > wrote: I'm available at 2pm. Would you be able to circulate a call in number, please, Bruce? SDNY_00016720 Page 11127 Pace 118 EFTA00138630 Assistant United States Attorney Southern District of New York New York, NY 10007 From: Bruce Barket Sent: Friday, August 30, 20191:25 PM To: Cc: Leisenring Subject: Re: MCC conditions we have a time for the call and perhaps a call in number? Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - 0 (516) 287 7230 - M Barket bacon On Aug 30, 2019, at 10:30 AM, Good morning all, Would 2 or 2:30 work? > wrote: I am running around this morning, have a meeting at 1, and am leaving at 3. Thanks, >» ' 8/29/2019 7:54 PM >» Received. discuss? Thanks, >; Aida would you all be free for a call tomorrow afternoon to SDNY_00016721 Page 11128 Pace 119 EFTA00138631 Assistant United States Attorney Southern District of Ncw York New York, NY 10007 From: Bruce Barket Sent: Thursday, August 29, 2019 5:25 PM To: Cc: (USANYS) Subject: MCC conditions >; Aida Leisenring >; tonyricco ( • Michael Bachrach I am writing as I have been asked to update everyone on the continuing problems at the facility. Mr. Tartaglione has not has books swapped out since was kind enough to it himself on August 15th. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as "You're threatening our lives" and "Give the big mouth his try" and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldn't stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasn't a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [P1 (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, olease notify us immediately by telephone or email and immediately deletesbist_00018722 Page 11129 Pace 120 EFTA00138632 Subject: RE: MCC conditions Sent: Fri, 30 Aug 2019 17:48:51 +0000 Thanks very much. Talk at 2pm. Assistant United States Attorney Southern District of New York New York, NY 10007 From: Bruce Barket Sent: Frida Au: ust 30, 2019 1:47 PM To: Cc: >; Aida Leisenrin: < >; Subject: Re: MCC conditions 1-800-977-8002 Participants Code - Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 1:26 PM, >; tonyricco >; MichaelBachrach wrote: I'm available at 2pm. Would you be able to circulate a call in number, please, Bruce? Assistant United States Attorney Southern District of New York Ne,A York. NI 10007 From: Bruce Barket Sent: Friday, August 30, 2019 1:25 PM SDNV_00016723 Page 121 EFTA00138633 To: Cc: Subject: Re: MCC conditions >>>" >; Aida Leisenrm < >; MIwe have a time for the call and perhaps a call in number? Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 10:30 AM, Good morning all. > wrote: >; tonyricco >; MichaelBachrach Would 2 or 2:30 work? 1 am running around this morning, have a meeting at 1, and am leaving at 3. Thanks, )11 c > 8/29/2019 7:54 PM >» Received. would you all be free for a call tomorrow afternoon to discuss? Thanks, Assistant United States Attorney Southern District of New York New York. NY 10007 From: Bruce Barket Sent: Thursday, August 29, 2019 5:25 PM To: >; Subject: MCC conditions Michael Bachrach ( I am writing as I have been asked to update everyone on the continuing problems at the facility. SDNY_00016724 Mr. Tartaglione has not has books swapped out since was kind enough to it himself on August Page 122 EFTA00138634 15th. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as "You're threatening our lives" and "Give the big mouth his try" and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldn't stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasn't a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 (P1 (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 SON1100016725 Page 123 EFTA00138635 RE: MCC conditions From Date 2019/08/30 14:06 Subject: RE: MCC conditions Attachments: TEXT.htm, Mime.822 M , we are all on the conference line—would you be able to join us? From: Bruce Barket < Sent: Frida Au ust 30, 2019 1:47 PM 1-800-977-8002 Participants Code - Subject: Re: MCC conditions Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket EpiteinsoM On Aug 30, 2019, at 1:26 PM, < > wrote: I'm available at 2pm. Would you be able to circulate a call in number, please, Bruce? Assistant United States Attorney Southern District of New York New York, NY 10007 From: Bruce Barket < SDNY_00016726 Page 11138 Pape 124 EFTA00138636 sent: a-may, August su, tu.w .vin YM To: Cc: Leisenring Subject: Re: MCC conditions >; MichaelBachrach we have a time for the call and perhaps a call in number? Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket fistPin rnm On Aug 30, 2019, at 10:30 AM, > wrote: Good morning all, Would 2 or 2:30 work? I am running around this morning, have a meeting at I, and am leaving at 3. Thanks, >>> ' 8/29/2019 7:54 PM >>> Received. discuss? Thanks, >; Aida ' <Maurene.Comey@usdoj gov> would you all be free for a call tomorrow afternoon to Corey Assistant United States Attorney Southern District of New York New York, NY 10007 From: Bruce Barket [ant• Thu ircrinv Ai Knott 74:1 7f 14 S•7S PM SONY_00016727 Page 11139 Pax 125 EFTA00138637 •00.••••• •••••1,..,1•••••, ••••••••••• ••••••••• U IVO To: Cc: Subject: MCC conditions >; Aida Leisenring >; tonyricco ( Michael Bachrach I am writing as I have been asked to update everyone on the continuing problems at the facility. Mr. Tartaglione has not has books swapped out since was kind enough to • it himself on August 15th. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as "You're threatening our lives" and "Give the big mouth his try" and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldn't stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasn't a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [P1 (516) 745 1245 [F) www.barketepstein.com 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 SONC00016728 Page 11140 Pace 126 EFTA00138638 Subject: RE: MCC conditions Sent: Fri. 30 Aug 2019 18:02:43 +0000 MI, we are all on the conference line—would you be able to join us? From: Bruce Barket < Sent: Frida Au st 30 2019 1:47 PM To: Cc: >; Aida Leisenrin >; Subject: Re: MCC conditions 1-800-977-8002 Participants Code - Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 1:26 PM, ; tonyricco >; MichaelBachrach ( wrote: I'm available at 2pm. Would you be able to circulate a call in number, please, Bruce? Assistant United States Attorney Southern District of New York New York. NY 10007 From: Bruce Barket Sent: Frida , Au ust 30, 2019 1:25 PM To: Cc: >; Aida Leisenrin: < <MCom Subject: Re: MCC conditions we have a time for the call and perhaps a call in number? usa do ov>; tonyricco >; MichaelBachrach Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road SDNY_00016729 Page 127 EFTA00138639 Garden City, NY 11530 (516) 745 1500 - 0 (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 10:30 AM, Good morning all, > wrote: Would 2 or 2:30 work? I am running around this morning, have a meeting at 1, and am leaving at 3. Thanks, >» " 8/29/2019 7:54 PM >» Received. , would you all be free for a call tomorrow afternoon to discuss? Thanks Assistant United States Attorney Southern District of New York New York. NY 10007 usdo.. ov From: Bruce Barket < Sent: Thursda August 29, 2019 5:25 PM To: Cc: Michael Bachrach Subject: MCC conditions I am writing as I have been asked to update everyone on the continuing problems at the facility. Mr. Tartaglione has not has books swapped out since was kind enough to. it himself on August 15th. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as "You're threatening our lives" and "Give the big mouth his try" and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldn't stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasn't a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP SDNY_00016730 Page 128 EFTA00138640 Re: MCC conditions From Bruce Barket Date 2019/08/30 13:47 Subject: Re: MCC conditions Attachments: TEXT.htm, Mime.822 1-800-977-8002 Participants Code - Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 1:26 PM, wrote: la€`"m available at 2pm. Would you be able to circulate a call in number, please, Bruce? Assistant United States Attorney Southern District of New York I St. Andrewa€T"'s Plaza New York, NY 10007 From: Bruce Barket >• MichaelBachrach Subject: Re: MCC conditions SDNV_00016731 Page 11148 Pax 129 EFTA00138641 we have a time for the call and perhaps a call in number? Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Eostein.com On Aug 30, 2019, at 10:30 AM, Good morning all, > wrote: Would 2 or 2:30 work? I am running around this morning, have a meeting at I, and am leaving at 3. Thanks, >>>' 8/29/2019 7:54 PM >>> Received. would you all be free for a call tomorrow afternoon to discuss? Thanks, Assistant United States Attorney Southern District of New York 1 St. Andrewie's Plaza New York. NY 10007 MI L usdoj.gov From: Bruce Barket Sent: Thursda August 29, 2019 5:25 PM To: Cc: >; Aida Leisenring >• ton ricco • Michael Bachrach Subject: MCC conditions SDNY_00016732 Page 11149 Pape 130 EFTA00138642 I am writing as I have been asked to update everyone on the continuing problems at the facility. Mr. Tartaglione has not has books swapped out since was kind enough to. it himself on August 15th. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as a€ceYoua€'"re threatening our livesa€ and a"€ceGive the big mouth his trya€ and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldna€'"'t stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasna€'"t a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [P1 (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 SONY_00016733 Page 11150 Page 131 EFTA00138643 From: To: n ri ch (USANYS)' Subject: Re: MCC conditions Sent: Fri. 30 Aug 2019 17:46:59 +0000 1-800-977-8002 Participants Code - Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 1:26 PM, I'm available at 2pm. Would you be able to circulate a call in number, please, Bruce? Assistant United States Attorney Southern District of New York New York. NY 10007 From: Bruce Barket Sent: Frida , Au: ust 30, 2019 1:25 PM To: Cc: >; Aida <1Swereold@usa.dol.gov> Subject: Re: MCC conditions Leisenrin In we have a time for the call and perhaps a call in number? Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - 0 (516) 287 7230 - M > wrote: tonyricco >; MichaelBachrach (USANYS) Barket Epstein.com On Aug 30, 2019, at 10:30 AM, wrote: SDNY_00016734 Page 132 EFTA00138644 Good morning all, Would 2 or 2:30 work? I am running around this morning, have a meeting at I. and am leaving at 3. Thanks, >» " < > 8/29/2019 7:54 PM >>> Received. would you all be free for a call tomorrow afternoon to discuss? Thanks, Assistant United States Attorney Southern District of New York New York, NY 10007 From: Bruce Barket Sent: Thursda August 29, 2019 5:25 PM To: Cc: Michael Bachrach Subject: MCC conditions I am writing as I have been asked to update everyone on the continuing problems at the facility. Mr. Tartaglione has not has books swapped out since was kind enough to it himself on August 151h. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as "You're threatening our lives" and "Give the big mouth his try" and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldn't stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasn't a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. 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 (Fl SDNY_00016735 Page 133 EFTA00138645 RE: update on social visit? From To Date Subject: Attachments: Bruce Barket 2019/08/29 17:18 RE: update on social visit? TEXT.htin, Mime.822 I am sorry, but that won't be sufficient. We had a conversation with back and they told us that, in light of the particular needs for preparation for a capital case, MCC would permit periodic social visits as needed. I did not raise this issue with the court because of what we were told. Perhaps I misunderstood. and a few weeks Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [P1 (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 From: Sent: Thursday, August 29, 2019 3:03 PM To: Bruce Barket Cc: r Subject: RE: update on social visit? Hi Bruce, After some discussion, MCC's administrators are prepared to offer your client a social phone call with his parents, which would be outside the normal phone schedule provided to inmates in Special Housing. If you fell that would be inadequate, please advise and and I will take the issue back to our administrator& ar m ( ou, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 SONY_00016736 Page 11158 Pace 134 EFTA00138646 >> > 8/28/2019 4:23 PM > » Hi Bruce, Our Exec staff are still discussing it. I should hopefully have an answer for you by tomorrow. In the meantime, can you give me any information about the "critical stage" in the case? I don't want to know anything that would violate privilege, but something very general (e.g. a plea is on the table, a cooperation agreement is on the table, etc.) might help our Exec staff evaluate the request. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 > » Bruce Barket < > 8/28/2019 3:40 PM > » Is there any update on a visit with his parents this week? 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 From: Sent: Wednesday, August 28, 2019 8:31 AM To: Cc: Subject: Re: meeting with Tartaglione No problem - I'll pull him down before the count. Thanks, SDNY_00016737 Page 11159 Pace 135 EFTA00138647 Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 > » Bruce Barket < > 8/28/2019 8:28 AM > » I know it is late notice but I am hoping to see Nick tonight at 5:00. Thank you Bruce A. Barket, Esq. Barket Epstein Kea ron Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 (PI (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 SONY_00016738 Page 11160 Pace 136 EFTA00138648 From: Bruce Bar et To: Cc: Subject: RE: update on social visit? Sent: Thu, 29 Aug 2019 21:15:56 +0000 I am sorry, but that won't be sufficient. We had a conversation with and a few weeks back and they told us that, in light of the particular needs for preparation for a capital case, MCC would permit periodic social visits as needed. I did not raise this issue with the court because of what we were told. Perhaps I misunderstood. 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 From: Sent: Thursday, August 29, 2019 3:03 PM To: Bruce Barket Cc: Subject: RE: update on social visit? Hi Bruce, After some discussion, MCC's administrators are prepared to offer your client a social phone call with his parents, which would be outside the normal phone schedule provided to inmates in Special Housing. If you fell that would be inadequate, please advise and and I will take the issue back to our administrators. Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 8/28/2019 4:23 PM > » Hi Bruce, Our Exec staff are still discussing it. I should hopefully have an answer for you by tomorrow. In the meantime, can you give me any information about the "critical stage" in the case? I don't want to know anything that would violate privilege, but something very general (e.g. a plea is on the table, a cooperation agreement is on the table, etc.) might help our Exec staff evaluate the request. Thanks, SON\100016739 Page 137 EFTA00138649 Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 P: f: 646-836-7665 >> > Bruce Barket < > 8/28/2019 3:40 PM >> > Is there any update on a visit with his parents this week? Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 WI (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 From: Sent: Wednesday, August 28, 2019 8:31 AM To: Bruce Barket Cc: Subject: Re: meeting with Tartaglione No problem - I'll pull him down before the count. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 >> > Bruce Barket < > 8/28/2019 8:28 AM > » I know it is late notice but I am hoping to see Nick tonight at 5:00. Thank you Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 (In (516) 745 1245 [F] This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidengritiPPRiaear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or Page 138 EFTA00138650 RE: update on social visit? From To Date Subject: Attachments: Hi Bruce, Bruce BarketS 2019/08/30 11:00 RE: update on social visit? TEXT.htm I will bring it back up to MCC administrators and get back to you. We should be able to accommodate it, but it would have to be on the normal SHU visiting day. I will get back to you as soon as I can. Thanks, > » Bruce Barket < > 8/29/2019 5:15 PM > » I am sorry, but that won't be sufficient. We had a conversation with and a few weeks back and they told us that, in light of the particular needs for preparation for a capital case, MCC would permit periodic social visits as needed. I did not raise this issue with the court because of what we were told. Perhaps I misunderstood. 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 From: Sent: Thursday, August 29, 2019 3:03 PM To: [aruce._6_,n_e_t_ic Cc: Subject: RE: update on social visit? Hi Bruce, After some discussion, MCC's administrators are prepared to offer your client a social phone call with his parents, which would be outside the normal phone schedule provided to inmates in Special Housing. If you fell that would be inadequate, please advise and and I will take the issue back to our administrators. SDNY_00016741 Page 11168 Parse 139 EFTA00138651 Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 Hi Bruce, 8/28/20194:23 PM >>> Our Exec staff are still discussing it. I should hopefully have an answer for you by tomorrow. In the meantime, can you give me any information about the "critical stage" in the case? I don't want to know anything that would violate privilege, but something very general (e.g. a plea is on the table, a cooperation agreement is on the table, etc) might help our Exec staff evaluate the request. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York NY 10007 p: - f.646-836-7665 > » Bruce Barket < > 8/28/2019 3:40 PM > » Is there any update on a visit with his parents this week? Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 WI (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 From: con+. IMAAnAerlaw As tni te+ •)A lnio 0.11 AM SCIAIY_00016742 Page 11169 Pape 130 EFTA00138652 VIUL“.JI natIC,J y, nuytnii. 6V, 6V1JVNl II -I To: Bruce Barket Cc: Subject: Re: meeting with Tartaglione No problem - I'll pull him down before the count. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 > » Bruce Barket < > 8/28/2019 8:28 AM > » I know it is late notice but I am hoping to see Nick tonight at 5:00. Thank you Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 IPI (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 SONY_00016743 Page 11170 Pape 141 EFTA00138653 Re: MCC conditions From Bruce Barket To Date 2019/08/30 13:47 Subject: Re: MCC conditions Attachments: TEXT.htm, Mime.822 I think so. Give me a moment Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country mad Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Fpstein.com On Aug 30, 2019, at 1:26 PM, wrote: la€'"m available at 2pm. Would you be able to circulate a call in number, please, Bruce? Assistant United States Attorney Southern District of New York I St. Andrewa€Thts Plaza New York, NY 10007 ) From: Bruce Barket Sent: Frida Au st 30, 2019 1:25 PM To: Cc: > >; Aida Leisenrin Subject: Re: MCC conditions ■ we have a time for the call and perhaps a call in number? Bruce Barket SDNY_00016744 Page 11174 Pace 142 EFTA00138654 Barket, Epstein, Kearon, Aldea & Lo I urco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 10:30 AM, Good morning all, > wrote: Would 2 or 2:30 work? I am running around this morning, have a meeting at 1, and am leaving at 3. Thanks, >>> ' 8/29/2019 7:54 PM >» Received. discuss? Thanks, would you all be free for a call tomorrow afternoon to Assistant United States Attorney Southern District of New York I St. Andrewa€T"'s Plaza New York, NY 10007 From: Bruce Barket Sent: Thursda August 29, 2019 5:25 PM To: Cc: <MComeyPusa.doj.gov>; >; Aida Leisenring >; ton ricco Michael Bachrach ) Subject: MCC conditions I am writing as I have been asked to update everyone on the continuing problems at the facility. SONY_00016745 Page 11175 Paie 143 EFTA00138655 Mr. Tartaglione has not has books swapped out since was kind enough to it himself on August 15th. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as a€ceYoua€'"re threatening our livesa€ and a€ceGive the big mouth his trya€ and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldna€'"t stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasna€'"t a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [P1 (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 SONY_00016746 Page 11176 Page 144 EFTA00138656 Subject: Re: MCC conditions Sent Fri, 30 Aug 2019 17:4621 +0000 I think so. Give me a moment Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 1:26 PM. I'm available at 2pm. Would you be able to circulate a call in number, please, Bruce? Assistant United States Attorney Southern District of New York New York, NY 10007 From: Bruce Barket < Sent: Frida , Au ust 30, 2019 1:25 PM To: Cc: Subject: Re: MCC conditions >; Aida Leisenrin: < we have a time for the call and perhaps a call in number? Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - 0 (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 10:30 AM, Good morning all, <MCome wrote: wrote: usa.do'. ov>. tonyricco >; MichaelBachrach Would 2 or 2:30 work? I am running around this morning, have a meeting at 1, and fffilirefiffilfg47 at 3. Page 145 EFTA00138657 Thanks. Subject: MCC conditions >» " 8/29/2019 7:54 PM >» Received. would you all be free for a call tomorrow afternoon to discuss? Thanks Assistant United States Attorney Southern District of New York New York. NY 10007 From: Bruce Barket , August 29, 2019 5:25 PM Michael Bachrach >; I am writing as I have been asked to update everyone on the continuing problems at the facility. Mr. Tartaglione has not has books swapped out since was kind enough to it himself on August 151". His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as "You're threatening our lives" and "Give the big mouth his try" and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldn't stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasn't a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [P1 (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 stricttmobOdte0i8 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 Page 146 EFTA00138658 Re: Defense private investigator/permission to NiSit mcc From To Date Sarah Sacks 2019/12/05 13:12 Subject: Re: Defense private investigator/permission to visit mcc Attachments: TEXT.htm, Mimc.822 Thank you, I appreciate it and will get back with the form as soon as possible. Sarah M. Sacks, Esq. EPSTEIN SACKS PLLC Office: 212.684.1230 Mobile: 917.566.6196 CONFIDENTIALITY: This email communication and any files transmitted with it may contain privileged and confidential information and are intended solely for the use of the individuals or entity to whom it has been addressed. If you have received this email in error, please delete it and notify the sender by return email. On Thu, Dec 5, 2019 at I :09 PM Hi Sarah, > wrote: Please have the PI fill out the application and NCIC form attached hereto starting at e will also need to provide a copy of his PI license and certificate. Please email it back to Ms. , cc'ed, so she can process it. Thank you, >> > Sarah Sacks <sarahsacksesqPgmail.com> 12/5/2019 12:24 PM >> > Hi . I'm not sure if you've already relocated but I'm hoping you can help or redirect me to someone who can. I have a private investigator we have a ointed under CiA coming to visit our client from out of town next week Monday and Tuesday. What Ewe need to to get him permission to come in with us for a legal visit? Thank you. Sent from my iPhone SDNV_00018749 Page 11184 Page 147 EFTA00138659 Re: Fwd: FW: Questions regarding MCC placement From To Date 2019/10/09 09:17 Subject: Re: Fwd: FW: Questions regarding MCC placement Attachments: TEXT.htm There are no psychology concerns. Thanks, Ph.D. Chief Psychologist Metropolitan Detention Center - Brooklyn 80 29th Street Brooklyn, NY 11232 x5362 National Suicide Prevention Lifeline 1-800-273-8255 Employee Assistance Program 1-800-222-0364 www.foh4you.com Confidentiality Notice: This e-mail and any attachments may contain confidential information intended solely for the use of the individual(s) or organization named above. If you received this message in error, please notify the sender immediately and delete this message, attachments, and any copies. Thank you. > » 10/8/2019 1:21 PM > » Please review the attached documentation, they want to extradite the inmate from England, however, England will not approve if he cannot be housed at MDC Brooklyn. They. not want the inmate housed at MCC New York base on what happened with Epstein. Please review and see if he can be housed here. Case Management Coordinator MDC Brooklyn P.O. Box 329001 Brooklyn, New York 11232 I ext.5020 (718) 840-5050 SONY_00016750 Page 11190 Pape 148 EFTA00138660 2019/07/25 09:20 To: It <I Subject: Fwd: hi and a question Re: hi and a question From To Date Subject: Re: hi and a question Attachments: TEXT.htm Thanks M, I'll take this to when I arrive in a few minutes. I saw multiple articles and Twitter posts late last night on this too Sent from my Verizon, Samsung Galaxy smartphone From: Date: 7/24/19 11:01 PM (GMT-05:00) F=. Ori al message ------ H ' 07/24/2019 23:01 >>> Sent from my Verizon, Samsung Galaxy smartphone ----- Original messa From: "Weiser, Ben" Date: 7/24/19 10:47 PM (GMT-05:00) To: Subject: hi and a question >>> "Weiser, Ben" 07/24/2019 22:47 >>> hi M, hope you are well. We saw an article tonight on someting called Radaronline reporting that Jeffrey Epstein attempted to commit suicide at the MCC (unsuccessfully.) Are you in a position to help me on that with some sort of confirmation or information. (Or to dispel its veracity?) thanks, Ben Benjamin Weiser r) nowt ••••• Wt.. 11/4 r..... tre.a. SDNY_00016751 Page 11219 0304 149 EFTA00138661 Fwd: Washington Post reporter reaching out From To Date 2019/07/23 20:31 Subject: Fwd: Washington Post reporter reaching out Attachments: TEXT.htm Please call me Thank you. Sem Om trtY Vcti >Dm Sumun$ Galax), snlimPhont ing iss:ist — From: Date: 7/23/19 6:32 PM (GMT-05-00 To: Cc: Subject: Fwd: Washington Post reporter reaching out ==. 07/23/2019 18:32 >>> if you get any inquiries on this situation or inmate ( see below). please decline to comment. Thats all we will say on this. MI. please forward my e Sent from my Verizon. Samsung Galaxy smartphoneediv> </div><div> </div><!— originalMessage Original message --e-/divD-cdiv>From: "Barrett, Devlin" e > </divD-r-div> <div>Subject: Washington Post reporter reaching out <Jdiv><div> >>> "Barrett, Devlin" <1 > 07/23/2019 18:00>>> Hi, I'm told that MCC inmate Jeffrey Epstein was found unconscious and unresponsive in his jail cell, and that there is currently art internal inquiry to determ 6330, can you please call? Thanks. Devlin Barrett Washington Post SDNY_00016762 Page 11224 Pax 150 EFTA00138662 End: Washington Post reporter reaching out From To Date 2019/07/23 20:16 Subject: Fwd: Washington Post reporter reaching out Attachments: TEXT.htm Sem from my *rum. Sonvays Galaxy smanplync From: Date: 7/23/19 6:32 PM(GMT-05-00 To: Cc: Subject: Fwd: Washington Post reporter reaching out >>> la 07/23/2019 18:32 >» M, if you get any inquiries on this situation or inmate ( see below). please decline to comment. Thats all we will say on this. please forward my c Sent from my Vcrizon. Samsung Galaxy smanphone<div> </cliv><div> </div><!— originalMcssagc Original message ----</div><div>From: "Barrett. Devlin" < > </div><div> <div>Subject: Washington Post reporter reaching out </div><div> </div> >» "Barrett, Devlin" <I 0712312019 18:00>>> Hi. Em told that MCC inmate Jeffrey Epstein was found unconscious and unresponsive in his jail cell, and that there is currently an internal inquiry to deterrn 6330, can you please call? Thanks. Devlin Barrett Washington Post SDNY_0001676.3 Page 11227 Pace 151 EFTA00138663 Fw: Statements by Mr. Tartaglione From Michael Bachrach ida LcisenringBRUCE K • FF KY To ( enneth J. Montgomery Esq, ,Michael BachrachTony Ricco Date 2019/11/19 14:22 Subject: Fw: Statements by Mr. Tartaglione Attachments: TEXT.htm, Mime.822 Him and ichael 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 Mess nP From: Bruce Barket To: Michael Bachrach (michael@mbachlaw.com) <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] SONY_00016754 Page 11230 Pace 152 EFTA00138664 www.barketepstein.com Ths 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) [maiIto 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 From: Sent: Monday, November 18, 2019 8:50 AM To: Bruce Barket < 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 •••••.'s Rrr inn CI•mrletrat ekl"..rlectfitIthrleciforsciain nnrn 11/1719(110 g•MI DRA SDNY_00016755 Page 11231 Pape 153 EFTA00138665 I./, MVO LJOI MVO. IP" I II II/ t-V I CI J.w I IVI 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 SONY_00016756 Page 11232 Pace 154 EFTA00138666 Sent: Tue, 19 Nov 2019 1 From: To: - cl C , BRUCE " lomery Esa" < -isenring >, >, Michael Bachrach > Subject: Fw: Statements by Mr. Tartaglione Him and 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 Mes From: Bruce Barket To: Michael Bachrach ) < 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] 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 From: (USANYS) [mailto:I Sen n N vember 18, 201 517 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 From: Sent: Monday, No T • Hi Bruce, Cc: Aida Leisenring <aleisenring Subject: Re: Statements by Mr. Tartaglione (USANYS) <JSweroold(ausa.doi.aov>: 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. Thank you, >>> 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 22rd 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 [Fl SON \100016758 Page 156 EFTA00138668 RE: update on social visit? From To Date Subject: Attachments: Bruce Barket 2019/08/29 17:30 RE: update on social visit? TEXT.htm, Mimc.822 Thanks for getting back to me. Let me know as soon as you can about a visit for next week. 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) www.barketeasteinsorq 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: Sent: Thursday, August 29, 2019 5:28 PM To: pflICE_Barket1 Cc: Subject: RE: update on social visit? Hi Bruce, MCC New York has permitted social visits despite disciplinary sanctions when the visit is specifically for mitigation purposes. Disciplinary sanctions notwithstanding, all pretrial inmates have the same access to family communication. monitored social visiting, monitored social phone calls, and monitored social mail. While I understand your client is a death penalty case, there are many inmates at MCC with very complex cases who have legal decisions they need to discuss with their families, and the methods available to them are the three methods I just mentioned. If a social phone call is insufficient, then we will raise the issue again with administrators to see if they will allow a social visit during your client's regular social visiting hours. However, please be advised that once your client returns to general population with regular phone access, In not anticipate administrators will be amenable to social visit requests unless they are being used as mitigation evidence. I am out of the office starting tomorrow, but will let you know once he discusses it with Exec staff. Thanks, SDNV_00016759 Page 11240 Page 157 EFTA00138669 Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 > » Bruce Barket < > 8/29/2019 5:15 PM > » I am sorry, but that won't be sufficient. We had a conversation with and a few weeks back and they told us that, in light of the particular needs for preparation for a capital case, MCC would permit periodic social visits as needed. I did not raise this issue with the court because of what we were told. Perhaps I misunderstood. 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] www.barketeostein.com This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not dear 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: Sent: Thursday, August 29, 2019 3:03 PM To: Bruce Barket Cc: Subject: RE: update on social visit? Hi Bruce, After some discussion, MCC's administrators are prepared to offer your client a social phone call with his parents, which would be outside the normal phone schedule provided to inmates in Special Housing. If you fell that would be inadequate, please advise and and I will take the issue back to our administrators. Tharam c ou, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: SONC00016760 Page 11241 Pace 158 EFTA00138670 f:646-836-7665 >> > Hi Bruce, 8/28/2019 4:23 PM > » Our Exec staff are still discussing it. I should hopefully have an answer for you by tomorrow. In the meantime, can you give me any information about the "critical stage" in the case? I don't want to know anything that would violate privilege, but something very general (e.g. a plea is on the table, a cooperation agreement is on the table, etc.) might help our Exec staff evaluate the request. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: - f.646-836-7665 > > > Bruce Barket < > 8/28/2019 3:40 PM > » Is there any update on a visit with his parents this week? 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] www barketepsteinsom 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: Sent: Wednesday, August 28, 2019 8:31 AM To: Bruce Barket Cc: Subject: Re: meeting with Tartaglione No problem - I'll pull him down before the count. Thanks, SDNY_00016761 Page 11242 Pape 159 EFTA00138671 Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: 1: 646-836-7665 > » Bruce Barket < > 8/28/2019 8:28 AM > » I know it is late notice but I am hoping to see Nick tonight at 5:00. Thank you 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 SONY_00016762 Page 11243 Pace 180 EFTA00138672 From: To: Cc: Subject: Sent: Thu, 29 Aug 2019 21:30:15 +0000 RE: update on social visit? Thanks for getting back to me. Let me know as soon as you can about a visit for next week. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [Pj (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 From: Sent: Thursday, August 29, 2019 5:28 PM To: Bruce Barket Cc: Subject: RE: update on social visit? Hi Bruce, MCC New York has permitted social visits despite disciplinary sanctions when the visit is specifically for mitigation purposes. Disciplinary sanctions notwithstanding, all pretrial inmates have the same access to family communications: monitored social visiting, monitored social phone calls, and monitored social mail. While I understand your client is a death penalty case, there are many inmates at MCC with very complex cases who have legal decisions they need to discuss with their families, and the methods available to them are the three methods I just mentioned. If a social phone call is insufficient, then we will raise the issue again with administrators to see if they will allow a social visit during your client's regular social visiting hours. However, please be advised that once your client returns to general population with regular phone access, I not anticipate administrators will be amenable to social visit requests unless they are being used as mitigation evidence. I am out of the office starting tomorrow, but will let you know once he discusses it with Exec staff. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 > » Bruce Barket < > 8/29/2019 5:15 PM >> > I am sorry, but that won't be sufficient. We had a conversation with and a few weeks back and they told us that, in light of the particular needs for preparation for a capital case, MCC would permit periodic social visits as needed. I did not raise this issue with the court because of what we were told. Perhaps I misunderstood. SDNY_00016763 Page 161 EFTA00138673 Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 (PI (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 From: Sent: Thursday, August 29, 2019 3:03 PM To: Bruce Barket Cc: Subject: RE: update on social visit? Hi Bruce, After some discussion, MCC's administrators are prepared to offer your client a social phone call with his parents, which would be outside the normal phone schedule provided to inmates in Special Housing. If you fell that would be inadequate, please advise and and I will take the issue back to our administrators. Thar .liou, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 >> > Hi Bruce, 8/28/2019 4:23 PM >>> Our Exec staff are still discussing it. I should hopefully have an answer for you by tomorrow. In the meantime, can you give me any information about the "critical stage' in the case? I don't want to know anything that would violate privilege, but something very general (e.g. a plea is on the table, a cooperation agreement is on the table, etc.) might help our Exec staff evaluate the request. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 SDNY_00016764 Page 162 EFTA00138674 > > > Bruce Barket < > 8/28/2019 3:40 PM >> > Is there any update on a visit with his parents this week? Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [PI (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 From: Sent: Wednesday, August 28, 2019 8:31 AM To: Bruce Barket Cc: Subject: Re: meeting with Tartaglione No problem - I'll pull him down before the count. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p1 f: 646-836-7665 > » Bruce Barket < > 8/28/2019 8:28 AM >> > I know it is late notice but I am hoping to see Nick tonight at 5:00. Thank you 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_00016765 Page 163 EFTA00138675 EPSTEIN # 76318-054 CPAP MACHINE. From To Date 2019/07/ 12 14:15 Subject: EPSTEIN # 76318-054 CPAP MACHINE. Attachments: TEXT.htm The above inmate said he had his CPAP machine with him at the time of his arrest He needs to have his CPAP machine for his medical condition. Is it in R and D or can we find out who has his CPAP machine? Thanks. SDNY_00016766 Page 11259 EFTA00138676 Jeffrey Epstein 19 cr 490 From To Date 2019/08/12 12:48 Subject: Jeffrey Epstein 19 cr 490 Attachments: Aug 12 letter.pdf, Mime.822 Please see attached letter from Judge Richard M. Berman. (See attached file: Aug 12 letter.pdf) SDNY_00016767 Page 11266 Paoe 165 EFTA00138677 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF Nrw YORK LIMED RYATRII 0OURTHOR0t, 500 PEARL ST Pirer NEW YORK, NEW YORK 10007 ea. mane or RICHARD M. BERMAN UNITED STATES saisrrniCTJHOGE August 12, 2019 Warden Metropolitan Correctional Center 150 Park Row New York, New York 10007 Dew Warden N'Diaye, Thank you for your letter of August 10.2019 regarding the lead: of Jeffrey Epstein. Mr. Epstein's death is a tragedy to everyone involved in his case. One open question, among others, is whether the investigations referenced in your letter will include the incident at MCC involving Mr. Epstein on or about July 23, 2019. To my knowledge, it has never been definitively explained what the BOP concluded about that incident. p}', k ICJ II I Richard M. Berman e Colleen McMahon District Executive Supervisory Staff Attorney MCC Michael Greco, U.S. Marshal Assistant United States Attorney Martin Weinberg, Counsel for Mr. Epstein SDNY_00016768 Page 106 EFTA00138678 Re: Federal prison suicides rising before Jeffrey Epstein's death From To Date 2019/08/23 13:14 Subject: Re: Federal prison suicides rising before Jeffrey Epstein's death Attachments: TEXT.htm Good point, thanks > » 8/23/2019 11:18 AM > » Hi , Rob has the information he gathered and sent to IPPA. I think an important point is that suicides in the community have also been on the rise. > 8/23/2019 10:39 AM > » Can I get any historical info you have? Thanks. https://www.usatoday.com/story/news/politics/2019/08/22/federal-prison-suicides-rising-before-jeffrey- epsteins-death/2070689001/ Sent from my Verizon, Samsung Galaxy smartphone SONY_00016769 Page 11292 EFTA00138679 Epstein, Jeffrey Edward, Reg. No. 73618-054 inhumation From To Date Subject: Attachments: 2019/08/10 16:35 Epstein, Jeffrey Edward, Reg. No. 73618-054 information TEXT.htm, Epstein, Jeffrey Edward, Reg. No. 73618-054 information.docx, So far this is the documentation I have in my possession. Associate Warden MCC New York 150 Park Row New York NY 10007 ext. 6451 SDNY_00016770 Page 11390 Paw 168 EFTA00138680 Documentation re: Epstein, Jeffrey Edward, Reg. No. 73618-054 (deceased) SENTRY PP44 PP37 (ARS, QTR) PP41 PP78 PPGO PD15 (Pending, Chrono) PP85 PR15 BOPWare label Administrative Detention (AD) Order 7/29/19 Inmate Personal Property Record (BP-A0383) Electronic Medical Record (BEMR) Psychology Data System (PDS) Psychology Observation Log books 7/8-10/19 and 7/24-30/19 Suicide Watch Chronological log 7/23 & 24/19 and Documentation re: Reyes, Efrain, Reg. No. 85993-054 (cellmate) Court documentation regarding WAB 8/9/19 SHU file Staff memos Dr. , Acting Chief Psychologist IDO , CO Miscellaneous Press Release Relevant emails Lt's log Friday, 8/9/19 SDNY_00016771 Page 169 EFTA00138681 SHU report - weekly review dated 8/8/19 SHU roster 8/8 & 9/19 SRO review roster 8/6/19 TRUSCOPE visual search log for Epstein TRUSCOPE all log for Epstein TRUSCOPE all log for Reyes Visual search log book Attorney Conference log book SDNY_00016772 Page 170 EFTA00138682 Re: meeting with tartaglione 8015 (1( 5:00 pm From To , Bruce Barket Date 2019/08/15 17:41 Subject: Re: meeting with tartaglione 8015 Op 5:00 pm Attachments: TEXT.htm Also, I have five books and four newspapers from the mailroom that just arrived today. I plan to take them up to SHU before I leave so the officers can give them to your client. Thanks Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: - f.646-836-7665 >> > Bruce Barket < > 8/15/2019 5:03 PM >>> Thanks. I am walking over now Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 15, 2019, at 4:43 PM, Hi Bruce, > wrote: Mr. Tartaglione was meeting with another member of your defense team earlier today. The plan was to have him remain in attorney conference after that meeting so he could review his discovery through the count. (It would also ensure he would already be down there when you arrived.) Without going into details, we're doing a special, more detailed count today at 4:00 PM for security procedures. I called attorney conference to make sure your client was still there, but they advised me that they had to send him back upstairs for this particular count. I will likely still be here when count clears so I'll try to assist in getting him down to attorney ennfnrnnres x els arIAI ,t- nt-treanIn he of I tAt'intnr1 r.. lot %ins I linenne +1-nt ‘ine rn-s‘t .nfeSDNYL410016773 Page 11435 Pride 171 EFTA00138683 LVI OCICI O..0 aD W.M.aly 03 1.0...330-0C, VW. 1 YVOI RCM 0./ MI. rim M IVO' WO% yvu illay u111v11u1141C1y have a wait tonight. If you want to reschedule for tomorrow evening, let me know and I'll make sure things go smoother. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f:646-836-7665 > » Bruce Barket < > 8/13/2019 5:02 PM > » Good afternoon, Can I meet with Nick on Thursday, August 15th at 5:00 p.m? By the way, I am imagine you have seen some of my comments repeating the complaints about MCC that I have been making for years. Please know that none of that was directed at you. You both have been professional, courteous and responsive to me, even in the face of my numerous complaints and emails. The press does not write about the good, but I have mentioned how much I admire the legal staff at MCC on several occasions. 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 SONY_00016774 Page 11436 Paw 172 EFTA00138684 RE: update on social visit? From To W, Bruce BarketM Date 2019/08/29 15:02 Subject: RE: update on social visit? Attachments: TEXT.htm Hi Bruce, After some discussion, MCC's administrators are prepared to offer your client a social phone call with his parents, which would be outside the normal phone schedule provided to inmates in Special Housing. If you fell that would be inadequate, please advise and and I will take the issue back to our administrators. -ar m < ou, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York NY 10007 p: - f.646-836-7665 >> > Hi Bruce, 8/28/20194:23 PM >>> Our Exec staff are still discussing it. I should hopefully have an answer for you by tomorrow. In the meantime, can you give me any information about the "critical stage" in the case? I don't want to know anything that would violate privilege, but something very general (e.g. a plea is on the table, a cooperation agreement is on the table, etc) might help our Exec staff evaluate the request. Thanks Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f 646-836-7665 SONY_00016775 Page 11440 Pape 173 EFTA00138685 >> > Bruce Barket < > 8/28/2019 3:40 PM >>> Is there any update on a visit with his parents this week? Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [PI (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 From: Sent: Wednesday, August 28, 2019 8:31 AM To: Bruce Barket Cc: Subject: Re: meeting with Tartaglione No problem - I'll pull him down before the count. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p• f: 646-836-7665 > » Bruce Barket < > 8/28/2019 8:28 AM > » I know it is late notice but I am hoping to see Nick tonight at 5:00. Thank you 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 transmit talls Sirkth SUNY_OUV16776 Page 11441 Pape 174 EFTA00138686 Re: MCC conditions From To Date 2019/08/30 13:25 Subject: Re: MCC conditions Attachments: TEXT.htm, Mime.822 we have a time for the call and perhaps a call in number? Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country mad Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 10:30 AM, Good morning all, Scannelltonyricco ecl I> wrote: Would 2 or 2:30 work? I am running around this morning, have a meeting at 1, and am leaving at 3. Thanks, >>> 1. PM >» Received. Thanks > 8/29/2019 7:54 would you all be free for a call tomorrow afternoon to discuss? Assistant United States Attorney Southern District of New York I St. Andrewatnis Plaza New York, NY 10007 SDNY_00016777 Page 11446 Pax 175 EFTA00138687 From: Bruce Barket Sent: Thursday, August 29, 2019 5:25 PM To: Subject: MCC conditions >; tonyricco Michael Bachrach I am writing as I have been asked to update everyone on the continuing problems at the facility. Mr. Tartaglione has not has books swapped out since was kind enough to it himself on August 15th. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as a€ceYoua€'"re threatening our livesa€ and a€ceGive the big mouth his trye€ and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldna€"'t stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasna€'"t a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. 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 SONC00016778 Page 11447 Page 1 PS EFTA00138688 Sent e: conditions Fri, 30 Aug 2019 17:24:31 +0000 we have a time for the call and perhaps a call in number? Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com On Aug 30, 2019, at 10:30 AM, > wrote: >, "tonyricco Good morning all, Would 2 or 2:30 work? I am running around this morning, have a meeting at 1, and am leaving at 3. Thanks, >» '1 > 8/29/2019 7:54 PM >» Received. , would you all be free for a call tomorrow afternoon to discuss? Thanks, Assistant United States Attorney Southern District of New York New York NY 10007 < From: Bruce Barket • Sent: Thursday, August 29, 2019 5:25 PM To: < > 1 j < Cc: Leisenrin• < >- ton ricco Michael Bachrach ; Aida Subject: MCC conditions I am writing as I have been asked to update everyone on the continuing problems at the facility. SDNY_00016779 Page Ill EFTA00138689 Mr. Tartaglione has not has books swapped out since was kind enough to it himself on August 15th. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as "You're threatening our lives" and "Give the big mouth his try" and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldn't stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasn't a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. 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 [1] 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_00016780 Page 178 EFTA00138690 Re: New Wrden From To Date 2019/11/05 13:04 Subject: Re: New Wrden Attachments: TEXT.htm Thank you, Your Honor. I will certainly miss NYC! I meant to ask, are there any inquiries for MDC to address tomorrow? Thank you again, Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 p: f. (646)836-7665 >> > • > 11/1/2019 1:36 PM >» Congratulations! But it means you'll have to move to Philly. :-) l-bn. Valerie Caproni United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 From: To: Date: 11/01/2019 12:37 PM Subject: Re: New Wrden Thank you, Your Honor, SDNY_00016781 Page 11454 Pape 179 EFTA00138691 I have advised the Warden and he will be prepared to speak as to language issues in medical and mental health. However, due to the ongoing outside investigation, we have no new information as to the Epstein investigation. To our knowledge, the matter is still under review by FBI, OIG, and the USAO. I also wanted to let you know personally before announcing it to the group that I have been selected as the incoming Deputy Regional Counsel for the Northeast Region in Philadelphia, PA, starting December 9. I have greatly enjoyed working with you and your staff and hope that I have been able to assist you when requested. I am sure my successor will continue to seek to work with all the stakeholders in doing what is best for both the general public and the inmate population. Best, Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 p• f. (646)836-7665 >> > < > 11/1/2019 9:51 AM >>> One other thing that you may be able to address (although this is more minor than the other issues): tow does the prison deal with prisoners who • not speak English when they need to see a doctor? There is some interest in hearing what is going on with the Epstein suicide investigation, but I suspect that is something the Warden cannot discuss. See you Wednesday. l-bn. Valerie Caproni United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 From To SONY_00016782 Page 11455 Parie 180 EFTA00138692 Date: 11/01/2019 07:56 AM Subject: Re: New Wrden Good morning Your Honor, My apologies, but I was out of the office unexpectedly yesterday due to a family emergency. Warden Petrucci and I will be in attendance at the CJAB next week. He indicates he will be addressing the issues that have delayed the attorney visiting study, to include those related to the union. He will also update the Court on the female unit at MCC. Please let us know if you need anything else. Thank you, Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 p: f: (646)836-7665 > > > < > 10/31/2019 10:39 AM >> > Will your new warden be able to attend the CJAB meeting next week? Will you be attending? If so, would you like to give a brief explanation of the union issues associated with the attorney waiting times study? Hon. Valerie Caproni United States District Judge Southern District of New York 40 Foley Square New York, W 10007 SDNY_00016783 Page 11456 Page 181 EFTA00138693 Re: New Wrden From To Date 2019/11/01 13:37 Subject: Re: New Wrden Attachments: TEXT.htm. Mime.822 Congratulations! But it means you'll have to move to Philly. :-) Hon. Valerie Caproni United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 11/01/2019 12:37 PM Re: New Wrden Thank you, Your Honor, I have advised the Warden and he will be prepared to speak as to language Sues in medical and mental health. However, due to the ongoing outside investigation, we have no new information as to the Epstein investigation. To our knowledge, the matter is still under review by FBI, OIG, and the USAO. I also wanted to let you know personally before announcing it to the group that I have been selected as the incoming Deputy Regional Counsel for the Northeast Region in Philadelphia, PA, starting December 9. I have greatly enjoyed working with you and your staff and hope that I have been able to assist you when requested. I am sure my successor will continue to seek to work with all the stakeholders in doing what is best for both the general public and the inmate population. Supervisory Staff Attorney CLC New York SDNY_00016784 Page 11461 Pa0e 182 EFTA00138694 Metropolitan Correctional Center 150 Park Row New York, New York 10007 p• f: (646)836-7665 >» < 11/1/20199:51 AM >>> One other thing that you may be able to address (although this is more minor than the other issues): how does the prison deal with prisoners who not speak English when they need to see a doctor? There is some interes

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I personally maintain contact with several individuals who are currently employed with the Bureau of Prisons as well as MCC New York. Three current MCC Staff Members very recently described to me the current sanitation conditions at the facility. One stated, "The facility is so disgusting it's like a prison in a third-world country. Cleaning supplies are not issued on a regular basis." The individual further advised, "Pest Control is horrible and ineffective, rats, mice and bugs are everywhere." Another Correctional Officer told me, "There are mice and bugs everywhere including inmates' cells." This information is consistent with my Court testimony on July 3, 2019, and my assessment in Paragraph 20 of my Declaration in the case of Mr. Motiwala. Further, it corroborates the many news reports, regarding the "rodent- infested MCC." On a different, yet equally concerning topic, an MCC Correctional Officer advised me this past week, that there is blatant racial discord withi

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Re: Hello From To Date 2019/07/30 15:14 Subject: Re: Hello Attachments: TEXT.htrn Sorry. Very busy with Epstein right now. I will get with you. Thanks. Associate Warden MCC New York 150 Park Row New York, New York 10007 > > > 7/30/2019 3:07 PM >>> I tried calling you to see if you would like to meet to get caught up with everything facilities is doing. Let me know when and if you want to get together. Thank You, SDNY_00016328 Page 8220 EFTA00138464 Epstein arrival at MCC From To Date 2019/08/12 13:17 Subject: Epstein arrival at MCC Attachments: TEXT.htm Please review for accuracy before I send toe. e, here is a timeline of his arrival at the MCC: 7/6/19: Arrived at NYM (Saturday) in the Receiving and Discharge area. Moved by staff to general population (apparently USMS did not indicate that he was a high profile inmate and staff were unaware that he was coming so no pkans had been established). 7/7/19: Warden idenfied him as high profile and moved him t

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Re: counsel having difficulty meeting with client From To Date 2019/07/07 18:39 Subject: Re: counsel having difficulty meeting with client Attachments: Mime.822 Thanks so much for the quick response (and solution). Mr. Weinberg should be able to get back to MCC in about 30 minutes so should be all set, and I'll let you know if he reaches out to me with any issues. thanks again, On Jul 7, 2019, at 18:28, > wrote: He's in with an attorney now (not sure which) but I cleared Mr. Weinberg to go in too. Sent from my Verizon, Samsung Galaxy smartphone Original messy e From: ' > Date: 7/7/19 6:18 PM To: >, Subject: RE: counsel having difficulty meeting with client >>>. " 07/07/2019 18:18 >» Massachusetts From: Sent: Sunda Jul 07 2019 18:18 To: >; Subject: Re: counsel having difficulty meeting with client Sorry just seeing this now. Where is he barred? Sent from my Verizon, Samsung Galaxy smartphone Original message SDNY_00016946 Page 13771 EFTA00138856 F

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