Requesting that the inquiry regarding Mr. Tartaglione's statements be considered a Rule 16 request for the penalty phase.
This document is an email chain between defense attorneys (Michael Bachrach and Bruce Barket) and the US Attorney's Office (USANYS). The attorneys are requesting records of statements made by inmate Mr. Tartaglione regarding Jeffrey Epstein's reported suicide attempt on July 22-23, 2019. The defense argues this is 'Rule 16' discovery material relevant to a 'penalty phase' (likely Tartaglione's capital case), while the government discusses the procedural requirements (Touhy regulations vs. Rule 16).
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