EFTA00015932.pdf
128 KB
Extraction Summary
9
People
5
Organizations
2
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Email chain / legal correspondence
File Size:
128 KB
Summary
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).
People (9)
| Name | Role | Context |
|---|---|---|
| Michael Bachrach | Attorney |
Sender of the final email; requesting Rule 16 material.
|
| Bruce Barket | Attorney |
Original requester of the information; Partner at Barket Epstein Kearon Aldea & LoTurco, LLP.
|
| Mr. Tartaglione | Inmate / Witness |
Inmate interviewed by BOP concerning Jeffrey Epstein's suicide attempt.
|
| Jeffrey Epstein | Subject |
Subject of the reported attempted suicide attempt on July 22/23, 2019.
|
| Tony Ricco | Attorney |
CC'd on the email chain.
|
| Bruce Koffsky | Attorney |
CC'd on the email chain.
|
| Kenneth J. Montgomery | Attorney |
CC'd on the email chain.
|
| Aida Leisenring | Attorney |
CC'd on the email chain.
|
| Assistant United States Attorney (Name Redacted) | Government Official |
USANYS official responding to the request regarding Rule 16 and Touhy regulations.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| USANYS |
United States Attorney for the Southern District of New York (implied by context).
|
|
| MCC |
Metropolitan Correctional Center.
|
|
| BOP |
Bureau of Prisons.
|
|
| USAO |
United States Attorney's Office.
|
|
| Barket Epstein Kearon Aldea & LoTurco, LLP |
Law firm representing the requester (Bruce Barket).
|
Timeline (2 events)
2019-07-22
Jeffrey Epstein's reported attempted suicide attempt (late hours of July 22 or early hours of July 23).
MCC (implied)
2019-07-23
Interview of Mr. Tartaglione by Bureau of Prisons regarding Epstein's suicide attempt.
MCC (implied)
Mr. Tartaglione
BOP Agents
Locations (2)
| Location | Context |
|---|---|
|
Office of Michael K. Bachrach, Esq.
|
|
|
Office of Barket Epstein Kearon Aldea & LoTurco, LLP.
|
Relationships (2)
Tartaglione was interviewed concerning Epstein's suicide attempt, implying proximity or witness status.
Sharing legal strategy and forwarding emails regarding the Tartaglione/Epstein matter.
Key Quotes (3)
"It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July 22nd or the early hours of July 23, 2019 concerning Jeffrey Epstein's reported attempted suicide attempt."Source
EFTA00015932.pdf
Quote #1
"please consider it as a Rule 16 request as we view this information as discoverable as Rule 16 material as to the penalty phase."Source
EFTA00015932.pdf
Quote #2
"Pursuant to FOIA/Privacy Act and Touhy regulations, we need a release from the inmate, Touhy letter, and subpoena for the request to be considered locally."Source
EFTA00015932.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (4,212 characters)
From: Michael Bachrach <[REDACTED]>
To: "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED]"
<[REDACTED]>
Cc: Tony Ricco <[REDACTED]>, BRUCE KOFFSKY <[REDACTED]>, "Kenneth J.
Montgomery Esq" <[REDACTED]>, Aida Leisenring
<[REDACTED]>, [REDACTED] <[REDACTED]>, "Michael Bachrach"
<[REDACTED]>
Subject: Fw: Statements by Mr. Tartaglione
Date: Tue, 19 Nov 2019 19:19:57 +0000
To: "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED]"
<[REDACTED]>
Cc: Tony Ricco <[REDACTED]>, BRUCE KOFFSKY <[REDACTED]>, "Kenneth J.
Montgomery Esq" <[REDACTED]>, Aida Leisenring
<[REDACTED]>, [REDACTED] <[REDACTED]>, "Michael Bachrach"
<[REDACTED]>
Subject: Fw: Statements by Mr. Tartaglione
Date: Tue, 19 Nov 2019 19:19:57 +0000
Hi [REDACTED] and [REDACTED]
Bruce B. has brought the following exchange to my attention. Yes, to the extent the request has been
made to you please consider it as a Rule 16 request as we view this information as discoverable as
Rule 16 material as to the penalty phase.
made to you please consider it as a Rule 16 request as we view this information as discoverable as
Rule 16 material as to the penalty phase.
Also, in light of your offer, we will hold off for now on pursuing the request with the MCC/BOP to avoid
duplicative efforts. We appreciate your assistance, as your aid could certainly speed things along.
duplicative efforts. We appreciate your assistance, as your aid could certainly speed things along.
--Michael
===========================
Michael K. Bachrach, Esq.
276 Fifth Ave., Suite 501
New York, NY 10001
tel: [REDACTED]
fax: [REDACTED]
cell: [REDACTED]
All other email to: [REDACTED]
Michael K. Bachrach, Esq.
276 Fifth Ave., Suite 501
New York, NY 10001
tel: [REDACTED]
fax: [REDACTED]
cell: [REDACTED]
All other email to: [REDACTED]
----- Forwarded Message -----
From: Bruce Barket <[REDACTED]>
To: Michael Bachrach [REDACTED]
Sent: Tuesday, November 19, 2019, 07:38:07 AM EST
Subject: FW: Statements by Mr. Tartaglione
From: Bruce Barket <[REDACTED]>
To: Michael Bachrach [REDACTED]
Sent: Tuesday, November 19, 2019, 07:38:07 AM EST
Subject: FW: Statements by Mr. Tartaglione
Received this
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road , Ste. 700
Garden City, NY 11530
[REDACTED]
www.barketepstein.com
EFTA00015932
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road , Ste. 700
Garden City, NY 11530
[REDACTED]
www.barketepstein.com
EFTA00015932
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
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: Monday, November 18, 2019 5:37 PM
To: [REDACTED]; Bruce Barket; [REDACTED]
Cc: Aida Leisenring
Subject: RE: Statements by Mr. Tartaglione
Sent: Monday, November 18, 2019 5:37 PM
To: [REDACTED]; Bruce Barket; [REDACTED]
Cc: Aida Leisenring
Subject: RE: Statements by Mr. Tartaglione
Bruce - To the extent your request is to the MCC/BOP, the request is governed by the procedures set forth below in [REDACTED]
email. To the extent the request is to our office pursuant to Rule 16, as a courtesy, we will look to see what statements are in
our possession and gather and produce them to you by the end of the week. The production will be pursuant to the
protective order in this case.
email. To the extent the request is to our office pursuant to Rule 16, as a courtesy, we will look to see what statements are in
our possession and gather and produce them to you by the end of the week. The production will be pursuant to the
protective order in this case.
[REDACTED]
Assistant United States Attorney
[REDACTED]
Assistant United States Attorney
[REDACTED]
From: [REDACTED]
Sent: Monday, November 18, 2019 8:50 AM
To: Bruce Barket <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED]
[REDACTED]
Cc: Aida Leisenring <[REDACTED]>
Subject: Re: Statements by Mr. Tartaglione
Sent: Monday, November 18, 2019 8:50 AM
To: Bruce Barket <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED]
[REDACTED]
Cc: Aida Leisenring <[REDACTED]>
Subject: Re: Statements by Mr. Tartaglione
Hi Bruce,
Pursuant to FOIA/Privacy Act and Touhy regulations, we need a release from the inmate, Touhy letter, and subpoena for
the request to be considered locally. Please also be advised that we would have to seek authority under Touhy through the
USAO.
the request to be considered locally. Please also be advised that we would have to seek authority under Touhy through the
USAO.
Thank you,
[REDACTED]
[REDACTED]
>>> Bruce Barket <[REDACTED]> 11/17/2019 5:03 PM >>>
It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July 22nd or
the early hours of July 23, 2019 concerning Jeffrey Epstein's reported attempted suicide attempt. Pease provide the record of
any statements made by Mr. Tartaglione, any written statements made by Mr. Tartaglione and any recording of any such
statements.
EFTA00015933
It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July 22nd or
the early hours of July 23, 2019 concerning Jeffrey Epstein's reported attempted suicide attempt. Pease provide the record of
any statements made by Mr. Tartaglione, any written statements made by Mr. Tartaglione and any recording of any such
statements.
EFTA00015933
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road , Ste. 700
Garden City, NY 11530
[REDACTED]
www.barketepstein.com
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road , Ste. 700
Garden City, NY 11530
[REDACTED]
www.barketepstein.com
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
EFTA00015934
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
EFTA00015934
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