EFTA00027031.pdf
118 KB
Extraction Summary
5
People
2
Organizations
1
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Email correspondence / legal negotiation
File Size:
118 KB
Summary
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.
People (5)
| Name | Role | Context |
|---|---|---|
| Andrew Patel | Defense Attorney |
Attorney representing the unnamed client ('Mr. [Redacted]'); negotiating with the government regarding disclosures.
|
| Jill Shellow | Attorney |
Cc'd on the email chain; likely co-counsel or colleague of Patel.
|
| Don Yannella | Attorney |
Cc'd on the email chain; likely co-counsel or colleague of Patel.
|
| Judge Torres | Judge |
Referenced as the judge presiding over the relevant case (likely Judge Analisa Torres).
|
| Mr. [Redacted] | Client/Witness |
Andrew Patel's client. Met with the Government office. There is concern about his safety if his name is disclosed. He...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States Government |
Referenced as 'the Government' and 'your Office'; prosecuting party.
|
|
| Law Office of Andrew G. Patel |
Legal practice of the sender.
|
Timeline (2 events)
Prior to 2019-12-20
Meeting between Mr. [Redacted] (Patel's client) and the Government Office.
Government Office
Mr. [Redacted]
Government Officials
Prior to 2019-12-20
Surveillance video recording that contradicts a statement made by Mr. [Redacted].
Unknown (Likely prison/MCC)
Locations (1)
| Location | Context |
|---|---|
|
Implied jurisdiction (SDNY, Judge Torres) and area code 212.
|
Relationships (2)
Patel refers to 'our client' and 'Mr. [Redacted]' throughout the emails.
Client met with the Office; Government seeks to disclose notes from this meeting; Patel argues client is not a witness.
Key Quotes (5)
"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."Source
EFTA00027031.pdf
Quote #1
"Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material."Source
EFTA00027031.pdf
Quote #2
"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."Source
EFTA00027031.pdf
Quote #3
"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."Source
EFTA00027031.pdf
Quote #4
"produce Mr. [REDACTED] name and your contact information to defense counsel on an AEO basis."Source
EFTA00027031.pdf
Quote #5
Full Extracted Text
Complete text extracted from the document (3,844 characters)
From: [REDACTED]
To: Andrew Patel <[REDACTED]>
Cc: Jill Shellow <[REDACTED]>, Don Yannella <[REDACTED]>, "[REDACTED]" <[REDACTED]>, "[REDACTED]" <[REDACTED]>
Subject: RE: [REDACTED]/Epstein
Date: Fri, 20 Dec 2019 22:56:20 +0000
To: Andrew Patel <[REDACTED]>
Cc: Jill Shellow <[REDACTED]>, Don Yannella <[REDACTED]>, "[REDACTED]" <[REDACTED]>, "[REDACTED]" <[REDACTED]>
Subject: RE: [REDACTED]/Epstein
Date: Fri, 20 Dec 2019 22:56:20 +0000
Thanks Andy, we will review and get back to you early next week.
-----Original Message-----
From: Andrew Patel <[REDACTED]>
Sent: Friday, December 20, 2019 5:14 PM
To: [REDACTED] <[REDACTED]>
Cc: Jill Shellow <[REDACTED]>; Don Yannella <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; Andrew Patel <[REDACTED]>
Subject: RE: [REDACTED]/Epstein
From: Andrew Patel <[REDACTED]>
Sent: Friday, December 20, 2019 5:14 PM
To: [REDACTED] <[REDACTED]>
Cc: Jill Shellow <[REDACTED]>; Don Yannella <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; Andrew Patel <[REDACTED]>
Subject: RE: [REDACTED]/Epstein
[REDACTED],
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
[REDACTED]
[REDACTED]
[REDACTED]
Attorney at Law
[REDACTED]
[REDACTED]
[REDACTED]
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of the communication is strictly prohibited. If you have received this e-mail in error, please notify me immediately by telephone at (212) 349-0230 and by return e-mail, and delete all copies of the message from your computer. Thank you.
EFTA00027031
-----Original Message-----
From: [REDACTED] [mailto:[REDACTED]]
Sent: Friday, December 20, 2019 10:01 AM
To: Andrew Patel
Cc: Jill Shellow; Don Yannella; [REDACTED]
Subject: RE: [REDACTED]/Epstein
From: [REDACTED] [mailto:[REDACTED]]
Sent: Friday, December 20, 2019 10:01 AM
To: Andrew Patel
Cc: Jill Shellow; Don Yannella; [REDACTED]
Subject: RE: [REDACTED]/Epstein
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. [REDACTED] 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] 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.
-----Original Message-----
From: Andrew Patel <[REDACTED]>
Sent: Friday, December 20, 2019 8:15 AM
To: [REDACTED] <[REDACTED]>
Cc: Andrew Patel <[REDACTED]>; Jill Shellow <[REDACTED]>; Don Yannella <[REDACTED]>
Subject: [REDACTED]/Epstein
From: Andrew Patel <[REDACTED]>
Sent: Friday, December 20, 2019 8:15 AM
To: [REDACTED] <[REDACTED]>
Cc: Andrew Patel <[REDACTED]>; Jill Shellow <[REDACTED]>; Don Yannella <[REDACTED]>
Subject: [REDACTED]/Epstein
[REDACTED]
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
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
[REDACTED]
[REDACTED]
Attorney at Law
[REDACTED]
[REDACTED]
Sent from my phone
EFTA00027032
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