Epstein Project

EFTA00029584.pdf

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pdf
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data-set-8

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Case 1:19-cr-00373-PGG Document 176 Filed 01/20/20 Page 1 of 3 
LAW OFFICES 
SCOTT A. SREBNICK, P.A. 
SCOTT A. SREBNICK.
• ALSO ADMITTED IN NEW YORK 
January 20, 2020 
Via ECF 
Honorable Paul G. Gardephe 
United States District Judge 
Thurgood Marshall U.S. Courthouse 
40 Foley Square 
New York, NY 10007 
Re: 
United States v. Avenatti, No. Si 19 Cr. 373 (PGGI 
Letter Concerning Mr. Avenatti's Prison Conditions 
Dear Judge Gardephe: 
201 S. Bisaynt Boulevard 
Suite 1210 
Miami. Florida 33131 
Tab 305-2819019 
Fax: 305-377-9937 
E-mail: scouesrebnicklaw.com 
InvW.MbniCklatre.CoM 
We write to inform the Court of Mr. Avenatti's conditions as a pretrial detainee and to 
request that the Court inquire into his custody status and direct the Bureau of Prisons to 
consider his immediate removal to general population. 
Under Mr. Avenatti's current 
conditions of confinement, we cannot effectively prepare for trial and Mr. Avenatti cannot 
meaningfully assist in his defense. 
As the Court is aware, Mr. Avenatti was remanded into custody last week, at the request 
of the United States Attorney for the Central District of California, on the theory that Mr. 
Avenatti violated his bail conditions in the CDCA because of financial transactions that 
prompted the prosecutors there to claim that he was an "economic danger." There was no 
allegation that Mr. Avenatti was a risk of flight or that he posed a physical danger to anyone 
or to himself. 
On Friday, January 17, 2020, after spending three nights in the Santa Ana jail, under 
solitary confinement conditions, Mr. Avenatti was flown from California to New York. Since 
then, he has been housed in the Special Housing Unit on the notorious 10-South of the MCC-
New York. It is the most secure floor in the entire facility. He is in a cell reportedly once 
occupied by El Chapo, on a floor that houses individuals charged with terrorism offenses. He 
is apparently under special administrative measures (SAMs), which almost completely 
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