EFTA00028448.pdf

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

From: Bruce Barke 
To: 
Cc: Aida Leisenrin 
Ton Ricco 
BRUCE 
KOFFSK 
Subject: Re: New mcc problems 
Date: Fri, 17 Jan 2020 17:07:05 +0000 
Thank you for the quick reply. I understand your position regarding communicating with all counsel of record. I 
assume that means your office won't be having separate communications (written or oral) with just appointed 
counsel. 
I. As I indicated, we will be filing a motion asking for an order allowing inspection of the location our client has 
been detained for what will likely be 4 years by the time the case is tried. Being able to present mitigating 
evidence to prevent Nick's execution is a "specific and pressing reason," at least in our view. We are happy to 
work with the BOP on reasonable conditions for the visit. 
2. I will wait to hear from her. Thanks for helping to move this alone. 
3. Thank you for the update on the hearing situation. I appreciate it. Knowing what the current situation is 
matters as does being to able to report back to the clients who brought the problem to my attention. 
4. This is a bit of a problem. I have been writing these emails since August. I do not think I should have to spell 
out how a requested visit helps in the preparation of the defense or how it will help our mitigation case. The 
tension between having a record made justifying the exception a ainst our right not to s ell out the details of our 
strategy was address back in August during a call that include 
. At that time we 
reached an agreement and we haven't had a problem until now. The requests have been no more than once a 
month or so and usually around court dates. We don't want to add to our workload or yours, but we can't have 
our client go months without seeing family as we prepare for a death penalty trial. Nor can provide the new level 
of detail being sought. Any further help you can provide would greatly appreciate. 
Bruce Barket 
Barket, Epstein, Kearon, Aldea & LoTurco 
666 Old Country road 
Garden City, NY 11530…
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