EFTA00028423.pdf
90.3 KB
Extraction Summary
5
People
4
Organizations
3
Locations
1
Events
3
Relationships
4
Quotes
Document Information
Type:
Email chain / legal correspondence
File Size:
90.3 KB
Summary
This document is an email chain from July 23-24, 2019, between defense attorney Martin G. Weinberg and an Assistant United States Attorney for the SDNY regarding a Protective Order for the Jeffrey Epstein case (indicated by attachment name '_JE_'). Weinberg outlines several objections to the government's draft, specifically concerning the handling of discovery materials at the MCC (where the defendant is held), the redaction of witness identities, and the labeling of FBI 302 reports. The chain concludes with the AUSA sending a revised order incorporating some edits for signature.
People (5)
| Name | Role | Context |
|---|---|---|
| Martin G. Weinberg | Defense Attorney |
Lead recipient/sender in email chain; negotiating terms of protective order.
|
| Reid Weingarten | Defense Attorney |
Cc'd on emails; mentioned as part of the defense team.
|
| Michael Miller | Defense Attorney |
Cc'd on emails; referred to as 'Mike' in text.
|
| [Redacted] | Assistant United States Attorney |
Sender of the initial and final emails; representing the Government/SDNY.
|
| Jeffrey Epstein | Defendant |
Implied by attachment name '_JE_' and reference to 'defendant at MCC'.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Law Office of Martin G. Weinberg, P.C. |
Defense counsel's firm.
|
|
| Southern District of New York (SDNY) |
Prosecuting office (US Attorney's Office).
|
|
| MCC |
Metropolitan Correctional Center; detention facility where the defendant is held.
|
|
| Court |
Judicial body handling the case.
|
Timeline (1 events)
2019-07-24
Negotiation of Protective Order terms between Defense (Weinberg) and Prosecution (SDNY).
Email Correspondence
Martin G. Weinberg
AUSA
Locations (3)
| Location | Context |
|---|---|
|
Address associated with Martin G. Weinberg's office.
|
|
|
Address of the SDNY/Assistant United States Attorney.
|
|
|
New York detention facility.
|
Relationships (3)
Both listed as recipients/cc on defense team emails.
Both listed as recipients/cc on defense team emails.
Exchanging emails negotiating legal terms.
Key Quotes (4)
"we need to distinguish between providing discovery electronically... and providing hard copies of discovery for the purpose of review... with the defendant at MCC"Source
EFTA00028423.pdf
Quote #1
"there is no need for allegations of potential obstruction or harm to witnesses in this case"Source
EFTA00028423.pdf
Quote #2
"Please advise if the Govt intends to mark all 302s as 'confidential' or just the identifying info"Source
EFTA00028423.pdf
Quote #3
"defense should be allowed to retain discovery through the filing date of a 2255"Source
EFTA00028423.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (3,191 characters)
From: [Redacted]
To: "Martin G. Weinberg" <[Redacted]>
Cc: [Redacted], "'Miller, Michael'" <[Redacted]>, 'Reid Weingarten' <[Redacted]>
Subject: RE: Protective Order
Date: Wed, 24 Jul 2019 21:58:36 +0000
Attachments: 2019-07-24, _JE,_protective_order_for_discovery_(RMB).pdf
To: "Martin G. Weinberg" <[Redacted]>
Cc: [Redacted], "'Miller, Michael'" <[Redacted]>, 'Reid Weingarten' <[Redacted]>
Subject: RE: Protective Order
Date: Wed, 24 Jul 2019 21:58:36 +0000
Attachments: 2019-07-24, _JE,_protective_order_for_discovery_(RMB).pdf
Marty,
Attached is a revised protective order, which incorporates the edits from our discussion today. If there are any issues or questions, please let us know. Otherwise, if you could please send us a signed copy, we'll take care of submitting it to the Court.
Thanks,
[Redacted]
From: Martin G. Weinberg <[Redacted]>
Sent: Wednesday, July 24, 2019 10:51 AM
To: [Redacted]; 'Martin Weinberg' <[Redacted]>
Cc: [Redacted]; 'Miller, Michael' <[Redacted]>; 'Reid Weingarten' <[Redacted]>
Subject: RE: Protective Order
Sent: Wednesday, July 24, 2019 10:51 AM
To: [Redacted]; 'Martin Weinberg' <[Redacted]>
Cc: [Redacted]; 'Miller, Michael' <[Redacted]>; 'Reid Weingarten' <[Redacted]>
Subject: RE: Protective Order
Hi [Redacted]
Some points for discussion or consideration re draft Protective Order:
Pg 2, line 2 - we consent to the entry of the Order but not necessarily all of the averments made by the Government in support of the Order
Pg 3 - par 2 - we need to distinguish between providing discovery electronically to others on the defense team (encrypt or password protected) and providing hard copies of discovery for the purpose of review by counsel or by counsel or others on defense team with the defendant at MCC
Pg 3 - par 3 -5 - these obligations should extend to Govt as well as defense
Pg 3 - par 4 - are you precluding public discussion of identity of witnesses already known to the defense i.e. known independent of the discovery
Pg 3/4 - par 5 - are you asking for redacted public filings or the entire filing being filed under seal - we could redact any quoting of the discovery or attaching of the discovery if that suffices
Pg 4-5 par 7 - there is no need for allegations of potential obstruction or harm to witnesses in this case - I would request that such language be redacted as unnecessary if we are not contesting the clause. Please advise if the Govt intends to mark all 302s as "confidential" or just the identifying info (names, addresses, etc).
Par 12 - defense should be allowed to retain discovery through the filing date of a 2255
Reid, Mike may have additional questions, points.
Available after 1 to discuss.
Thanks
Marty
Some points for discussion or consideration re draft Protective Order:
Pg 2, line 2 - we consent to the entry of the Order but not necessarily all of the averments made by the Government in support of the Order
Pg 3 - par 2 - we need to distinguish between providing discovery electronically to others on the defense team (encrypt or password protected) and providing hard copies of discovery for the purpose of review by counsel or by counsel or others on defense team with the defendant at MCC
Pg 3 - par 3 -5 - these obligations should extend to Govt as well as defense
Pg 3 - par 4 - are you precluding public discussion of identity of witnesses already known to the defense i.e. known independent of the discovery
Pg 3/4 - par 5 - are you asking for redacted public filings or the entire filing being filed under seal - we could redact any quoting of the discovery or attaching of the discovery if that suffices
Pg 4-5 par 7 - there is no need for allegations of potential obstruction or harm to witnesses in this case - I would request that such language be redacted as unnecessary if we are not contesting the clause. Please advise if the Govt intends to mark all 302s as "confidential" or just the identifying info (names, addresses, etc).
Par 12 - defense should be allowed to retain discovery through the filing date of a 2255
Reid, Mike may have additional questions, points.
Available after 1 to discuss.
Thanks
Marty
Martin G. Weinberg, Esq.
[Redacted]
[Redacted]
EFTA00028423
Boston, MA 02116
[Redacted]
================================This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited.
[Redacted]
================================This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited.
From: [Redacted]
Sent: Tuesday, July 23, 2019 7:02 PM
To: Martin G. Weinberg <[Redacted]>
Cc: [Redacted]
Subject: Protective Order
Sent: Tuesday, July 23, 2019 7:02 PM
To: Martin G. Weinberg <[Redacted]>
Cc: [Redacted]
Subject: Protective Order
Marty,
Following up on our conversation this morning, I’m attaching the proposed protective order we discussed. If you have any questions, or think it would be productive to schedule a call to discuss, please let us know.
Thanks,
[Redacted]
[Redacted]
Assistant United States Attorney
Southern District of New York
One Saint Andrew’s Plaza
New York, NY 10007
[Redacted]
[Redacted]
Assistant United States Attorney
Southern District of New York
One Saint Andrew’s Plaza
New York, NY 10007
[Redacted]
EFTA00028424
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