EFTA00017953.pdf

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pdf

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data-set-8

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U.S. Department of Justice 
United States Attorney 
Southern District of New York 
United States Courthouse 
300 Quarropas Street 
White Plains, New Yor* 10601 
January 9, 2020 
BY ECF 
The Honorable Kenneth M. Karas 
United States District Judge 
Southern District of New York 
300 Quarropas Street 
White Plains, NY 10601 
Re: 
United States v. Nicholas Tartaglione, S4 16 Cr. 832 (KMK) 
Dear Judge Karas: 
The Government respectfully submits this letter to provide a further update to the Court 
regarding the defense's request for video footage from outside the defendant's cell at the 
Metropolitan Correctional Center ("MCC") on July 22 — July 23, 2019. 
On or about December 
19, 2019, the Government informed the Court and defense counsel that it had confirmed with MCC 
staff that the requested video had been preserved, and that the Government was working to obtain 
a copy from MCC. As set forth in greater detail below, the Government has learned that the MCC 
inadvertently preserved video from the wrong tier within the MCC, and, as a result, video from 
outside the defendant's cell on July 22 — 23, 2019 (Le. the requested video) no longer exists. 
On or about July 23, 2019, at approximately 1:27 a.m., MCC corrections officers responded 
to the cell ("Cell-1") that the defendant shared with Jeffrey Epstein. On or about July 25, 2019, 
defense counsel requested that MCC preserve video footage from outside the defendant's cell from 
July 22, 2019 at 11:00 p.m. through July 23, 2019 at 4:00 a.m. From speaking with MCC legal 
counsel, the Government understands that in response to this request, MCC legal counsel looked 
up the defendant's cell number in the MCC computer system and thereafter requested that MCC 
staff preserve video from outside of that cell for the requested time period. An MCC staff member 
confirmed that the video had been preserved. 
On or about January 3, 2020, the MCC provided the Government with a copy of the video 
that it had preserved, which the …

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