EFTA00027031.pdf

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

From: 
To: Andrew Patel -"Ma 
Cc: Jill Shellow MEW, 
Don Yannella
Subject: RE: 
Epstein 
Date: Fri, 20 Dec 2019 22:56:20 +0000 
Thanks Andy, we will review and get back to you early next week. 
 
Original Message 
From: Andrew Patel ilMila> 
Sent: Frida December 20 2019 5:14 PM 
To: 
Cc: Jill Shellow 
Subject: RE: 
pstein 
We have attached a proposed disclosure cover letter that is modeled on a letter sent by the Government in United 
States v. Madonna, 17 Cr. 89 (CS). We have also attached proposed redacted disclosures. As you and I discussed, 
we offer this as a means to ensure our client's safety while permitting the Government to comply with what you 
believe are your disclosure obligations. 
As an alternative, we are willing to apply under seal to Judge Tones for a Protective Order to preclude the 
disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not 
believe that this is in fact Brady material, but rather is an error made by our client that we understand is 
contradicted by the surveillance video evidence. While we applaud your efforts, we have an obligation to make 
sure that our client is not harmed by the possible release of the fact that he met with your Office. 
We understand that you have time constraints. Please let us know how you want to proceed so that we can file a 
motion before Judge Tones promptly if that is necessary. 
Andy 
Andrew G. Patel 
Attorney at Law 
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