EFTA00030148.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: in" 
To: Andrew Patel -"Ma 
Cc: Jill Shellow MEW, 
Don Yannella
Subject: Re: 
Epstein 
Date: Thu, 26 Dec 2019 13:37:54 +0000 
Andy, 
Three issues: 
I. We plan to produce the redacted notes to the defense pursuant to the protective order, and the name on an AEO 
basis to defense counsel. Your letter states that both will be provided on an AEO, which misstates our intention. 
2. When we discussed this, we understood that this would not be submitted to defense counsel prior to Judge 
Torres ruling on your request. There is no language in the letter to that effect, and it seems appropriate to add it. 
3. Please add "to the defense" in the first letter to make clear to the Court that you are intervening in our 
production of discovery to defense counsel in this matter (and not, for instance, in a disclosure to the public or 
any other entity). 
Thanks. 
On Dec 25, 2019, at 10:25 AM, Andrew Patel 
wrote: 
We have attached a copy (draft) of our letter to Judge Torres. Please let me know your thoughts. We would 
like to get this to Judge Torres or if she is not available, the Part I Judge, tomorrow. 
Sony to bother you during a holiday, 
Andy 
Andrew G. Patel 
Attorney at Law 
From: 
Sent: Friday, December 20, 2019 6:36 PM 
To: Andrew Patel a> 
Cc: Jill Shellow a; 
Don Yannella .cla; 
>; 
) 
Subject: RE: a/Epstein 
EFTA00030148


Andy, 
We cannot agree to these redactions, and think it would be appropriate for you to file a motion before Judge Torres, under 
seal and copying the Government (but ex parte as to the defense). Could you please send us a copy of the letter before 
you file it, so that we can ensure that our position is accurately represented? Thanks very much. 
----Original Message---
From: Andrew Patel <I 
Sent: Friday, December 20, 2019 5:14  PM 
To: 
) 
Cc: Jill Shellow 
• 
Subject: RE: 
pstein 
>; Don Yannella 
I>; Andrew Patel 
We have attached a proposed disclosure cover letter that is modeled on a letter sent by the Government in United States v. 
M…
Open in the interactive archive →