Re: [Redacted]/Epstein

Please send us a copy of the disclosure that you are considering as to Mr. [REDACTED]. Seeing the planned disclosure about our client will help us fashion a means of addressing the concerns we discussed last night.
Many thanks,
Andy

Andrew G. Patel
Attorney at Law

Sent from my phone

Andy,

Attached are unredacted and redacted copies of the notes. As discussed, we intend to produce redacted copies of the notes pursuant to the protective order, and produce Mr. name and your contact information to defense counsel on an AEO basis. The file name will be changed to the bates number so it will not include his name.

I'm also copying my co-counsel [REDACTED] and [REDACTED] please include them on emails going forward. Finally, [REDACTED] is aware that we are providing these notes to you.

Thanks, and please feel free to give us a call to discuss.

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 Torres 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 Torres promptly if that is necessary.

Andy

Andrew G. Patel
Attorney at Law

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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.

Just to be clear.

1. Your Ian is to turn over the redacted notes to the defendants and counsel. Additionally you plan to provide ' name on an AEO basis. If I have that right, we will revise the letter.

2. You are agreeing to wait on disclosing this material until after Judge Torres rules on our application. Again, we will revise the letter to reflect that.

3. We will make that modification to the letter that this is a disclosure to the defense not the public. Thanks Andy