EFTA00021532.pdf
105 KB
Extraction Summary
5
People
3
Organizations
3
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Email thread (legal correspondence)
File Size:
105 KB
Summary
This document is an email chain from August 2, 2019, between the US Attorney's Office (SDNY) and Defense Counsel regarding the Jeffrey Epstein case. The correspondence details a dispute over whether specific discovery materials, including statements to law enforcement and cell site data, should be filed under seal or publicly with redactions. The prosecution accuses the defense of violating a protective order by publicly filing sensitive exhibits, while the defense discusses logistical issues regarding getting the defendant's affidavit signed at the MCC without the legal team acting as witnesses.
People (5)
| Name | Role | Context |
|---|---|---|
| Michael Bachrach | Defense Attorney |
CC'd on the email chain: michael@mbachlaw.com
|
| bkoffsky | Defense Attorney |
CC'd on the email chain: bkoffsky@snet.net
|
| Assistant United States Attorney (Redacted) | Prosecutor |
Sender of emails from USANYS, discussing protective order violations
|
| Defense Counsel (Redacted) | Defense Attorney |
Sender of emails from Garden City, NY firm; discussing motions and notary issues
|
| Jeffrey Epstein (Implied/Redacted) | Defendant |
Referred to as the person needing to sign an affidavit at MCC (Metropolitan Correctional Center). Context matches the...
|
Organizations (3)
Timeline (2 events)
Locations (3)
| Location | Context |
|---|---|
Relationships (2)
CC'd on privileged attorney communications.
Defendant (Epstein)
→
Incarceration
→
MCC
Reference to signing affidavit at MCC.
Key Quotes (3)
"We noticed that you publicly filed four documents that were marked sensitive (Exhibits A through D to your cell site motion) in violation of the protective order."Source
EFTA00021532.pdf
Quote #1
"affidavit hasn't been signed because the only regular access to a notary are members of his legal team and we don't want to witness his signature."Source
EFTA00021532.pdf
Quote #2
"We will have him sign it through whatever the process is at MCC or in open court at our next appearance."Source
EFTA00021532.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (4,273 characters)
From: [Redacted] (USANYS) <[Redacted]>
To: [Redacted] <[Redacted]>, "[Redacted]"
<[Redacted]>
Cc: [Redacted]
[Redacted]
Subject: RE: motions under seal?
Date: Fri, 02 Aug 2019 15:49:38 +0000
To: [Redacted] <[Redacted]>, "[Redacted]"
<[Redacted]>
Cc: [Redacted]
[Redacted]
Subject: RE: motions under seal?
Date: Fri, 02 Aug 2019 15:49:38 +0000
[Redacted],
As you know, the protective order distinguishes between all discovery and that marked "sensitive," and it is the sensitive discovery that cannot be publicly filed. [Redacted] statements to law enforcement do not fall into the sensitive category, so they should be publicly filed. We'd ask that, consistent with the protective order, any sensitive discovery and references to cooperators be redacted in your public filings. Along the same lines, we noticed that you publicly filed four documents that were marked sensitive (Exhibits A through D to your cell site motion) in violation of the protective order. We will be asking the Court to remove them from the docket and you will need to refile.
[Redacted]
Assistant United States Attorney
[Redacted]
Assistant United States Attorney
[Redacted]
From: [Redacted] <[Redacted]>
Sent: Friday, August 2, 2019 11:33 AM
To: [Redacted] (USANYS) <[Redacted]>; [Redacted] <[Redacted]>
Cc: [Redacted] <[Redacted]>; [Redacted] ([Redacted]) <[Redacted]>; Michael Bachrach (michael@mbachlaw.com) ; bkoffsky@snet.net
Subject: RE: motions under seal?
Sent: Friday, August 2, 2019 11:33 AM
To: [Redacted] (USANYS) <[Redacted]>; [Redacted] <[Redacted]>
Cc: [Redacted] <[Redacted]>; [Redacted] ([Redacted]) <[Redacted]>; Michael Bachrach (michael@mbachlaw.com) ; bkoffsky@snet.net
Subject: RE: motions under seal?
I don't think that will satisfy our concern about revealing the statements and certainly not something we can do today or easily. Nor do I want the extra work.
[Redacted]
[Redacted]
[Redacted]
Garden City, NY 11530
[Redacted]
[Redacted]
[Redacted]
[Redacted]
Garden City, NY 11530
[Redacted]
[Redacted]
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments
From: [Redacted] (USANYS) [mailto:[Redacted]]
Sent: Friday, August 02, 2019 11:26 AM
To: [Redacted]; [Redacted] ([Redacted])
Cc: [Redacted]; [Redacted] ([Redacted]); Michael Bachrach (michael@mbachlaw.com); bkoffsky@snet.net
Subject: RE: motions under seal?
Sent: Friday, August 02, 2019 11:26 AM
To: [Redacted]; [Redacted] ([Redacted])
Cc: [Redacted]; [Redacted] ([Redacted]); Michael Bachrach (michael@mbachlaw.com); bkoffsky@snet.net
Subject: RE: motions under seal?
EFTA00021532
[Redacted],
It is a little difficult to know what needs to be sealed/redacted in the abstract. Out of an abundance of caution, can you file the documents with any reference to evidence/discovery and cooperators redacted? We can then review the unredacted version and discuss what, if anything, can be unredacted for the public version.
[Redacted]
Assistant United States Attorney
[Redacted]
Assistant United States Attorney
[Redacted]
From: [Redacted] <[Redacted]>
Sent: Friday, August 2, 2019 11:03 AM
To: [Redacted] ([Redacted]) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Cc: [Redacted] <[Redacted]>; [Redacted] ([Redacted]) <[Redacted]>; [Redacted]
[Redacted]
Subject: motions under seal?
Sent: Friday, August 2, 2019 11:03 AM
To: [Redacted] ([Redacted]) <[Redacted]>; [Redacted] (USANYS) <[Redacted]>
Cc: [Redacted] <[Redacted]>; [Redacted] ([Redacted]) <[Redacted]>; [Redacted]
[Redacted]
Subject: motions under seal?
[Redacted], [Redacted],
Our motions will be ready to go out in a few hours., One is straight forward legal argument about the cell tower data, which we don't have a problem filing. The other motion deals with the statements to the police and by necessity we discuss the statements in detail. We also discuss some of the discovery and the cooperating witnesses. What is the Government position about filing that motion under seal?
Also, [Redacted] affidavit hasn't been signed because the only regular access to a notary are members of his legal team and we don't want to witness his signature. We will have him sign it through whatever the process is at MCC or in open court at our next appearance.
[Redacted]
[Redacted]
[Redacted]
Garden City, NY 11530
[Redacted]
[Redacted]
[Redacted]
[Redacted]
Garden City, NY 11530
[Redacted]
[Redacted]
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments
EFTA00021533
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