Proposing a disclosure cover letter modeled on US v. Madonna to ensure client safety. Arguing the material is not Brady/3500/Rule 16 but an error contradicted by surveillance video. Threatening to file motion for Protective Order before Judge Torres.
This document is an email chain from December 20, 2019, between attorney Andrew Patel and government prosecutors regarding the disclosure of information about a client of Patel's in the Epstein case context (likely related to the prison guards' prosecution). Patel argues against full disclosure, citing client safety concerns, and claims his client is not a witness but rather made an error in a statement that is 'contradicted by the surveillance video evidence.' The government proposes disclosing the client's identity to defense counsel only on an 'Attorneys' Eyes Only' (AEO) basis.
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