EFTA00022088.pdf

Type: pdf
Source set: data-set-8

Extracted text

Request #1 (8/13/19)
(1) The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds
on July 22 and 23, and Aug. 9 and 10. — the sign-hi log in the SHU is signed by supervisors
when they visit the SHU and does not contain dines. Both the log and the 30-minute round
forms and count slips are subject to the protective order in the Noel case and should not be
produced ahead of triaL
(2) All quarter entries (showing which cells he was housed in) for Jeffrey Epstein at MCC. I
don't see why this necessarily needs to be held back; but at the same dine I think it's entirely
defensible to not produce piecemeal the BOP records related to Epstein prior to triaL
(3) The CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC. I don't believe he
had any separates. I don't feel strongly about the CIM clearance.
(4) The chronological disciplinary records for Jeffrey Epstein at MCC. This would only include
the 7/23 suicide attempt, which should not be disclosed prior to trial because we may have
witnesses testify about it. I would think this could be released after trial.
(5) The intake screening form for Jeffrey Epstein at MCC.
(6) The security designation records for Jeffrey Epstein at MCC.
(7) The inmate profile for Jeffrey Epstein at MCC.
(8) All incident reports related to Jeffrey Epstein at MCC.
(9) All medical reports related to Jeffrey Epstein at MCC.
I do not think we should produce the above, which are subject to the Protective Order, could
likely be produced in some fashion after trial, and relate to topics that witnesses will testify
about at trial.
(10) The signed visitor log for Jeffrey Epstein at MCC.
He did not have any visitors other than legal visitors — query whether this can be produced.
(11) Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who
attended.
(12) All records generated from the meeting at MCC during which it was decided that Jeffrey
Epstein would be taken …

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