EFTA00022088.pdf
127 KB
Extraction Summary
2
People
4
Organizations
3
Locations
4
Events
1
Relationships
5
Quotes
Document Information
Type:
Internal legal strategy memo / discovery response draft
File Size:
127 KB
Summary
This document contains an annotated list of three discovery requests (dated 8/13/19 and 12/19/19) regarding Jeffrey Epstein's detention at the MCC. The text includes internal commentary (in bold italics) advising against the production of most documents—including video footage, round logs, and psychological reports—citing a protective order in the 'Noel case' and pending trial testimony. Significantly, the document asserts that logs of Epstein's phone calls and emails (Corrlinks) while at the MCC do not exist, and states he had no visitors other than legal counsel.
People (2)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Inmate / Subject |
Subject of the discovery requests regarding his detention, suicide attempt, and death.
|
| Noel | Case Subject |
Mentioned in reference to a 'Protective Order in the Noel case' governing document release.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MCC |
Metropolitan Correctional Center, where Epstein was housed.
|
|
| BOP |
Bureau of Prisons, agency holding the records.
|
|
| U.S. Attorney's Office |
Mentioned regarding correspondence about Epstein.
|
|
| SHU |
Special Housing Unit within the MCC.
|
Timeline (4 events)
2019-07-22
Dates of interest for MCC staff rounds and overtime sheets (coincides with first incident).
MCC Special Housing Unit
MCC Staff
Jeffrey Epstein
2019-08-09
Dates of interest for MCC staff rounds and overtime sheets (coincides with suicide).
MCC Special Housing Unit
MCC Staff
Jeffrey Epstein
2019-08-10
Dates of interest for MCC staff rounds and overtime sheets (coincides with suicide).
MCC Special Housing Unit
MCC Staff
Jeffrey Epstein
Locations (3)
| Location | Context |
|---|---|
|
Metropolitan Correctional Center (New York)
|
|
|
Specific unit within MCC
|
|
|
Specific wing/area within the Special Housing Unit
|
Relationships (1)
Documents related to Epstein are subject to a protective order in the 'Noel case'.
Key Quotes (5)
"He did not have any visitors other than legal visitors"Source
EFTA00022088.pdf
Quote #1
"The full log of Mr. Epstein’s phone calls to and from the MCC. Does not exist."Source
EFTA00022088.pdf
Quote #2
"All email correspondence to and from Mr. Epstein... Does not exist."Source
EFTA00022088.pdf
Quote #3
"This would only include the 7/23 suicide attempt, which should not be disclosed prior to trial because we may have witnesses testify about it."Source
EFTA00022088.pdf
Quote #4
"Both the log and the 30-minute round forms and count slips are subject to the protective order in the Noel case"Source
EFTA00022088.pdf
Quote #5
Full Extracted Text
Complete text extracted from the document (3,600 characters)
Request #1 (8/13/19)
(1) The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10. – the sign-in log in the SHU is signed by supervisors when they visit the SHU and does not contain times. Both the log and the 30-minute round forms and count slips are subject to the protective order in the Noel case and should not be produced ahead of trial.
(2) All quarter entries (showing which cells he was housed in) for Jeffrey Epstein at MCC. I don't see why this necessarily needs to be held back; but at the same time I think it's entirely defensible to not produce piecemeal the BOP records related to Epstein prior to trial.
(3) The CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC. I don't believe he had any separates. I don't feel strongly about the CIM clearance.
(4) The chronological disciplinary records for Jeffrey Epstein at MCC. This would only include the 7/23 suicide attempt, which should not be disclosed prior to trial because we may have witnesses testify about it. I would think this could be released after trial.
(5) The intake screening form for Jeffrey Epstein at MCC.
(6) The security designation records for Jeffrey Epstein at MCC.
(7) The inmate profile for Jeffrey Epstein at MCC.
(8) All incident reports related to Jeffrey Epstein at MCC.
(9) All medical reports related to Jeffrey Epstein at MCC.
I do not think we should produce the above, which are subject to the Protective Order, could likely be produced in some fashion after trial, and relate to topics that witnesses will testify about at trial.
(10) The signed visitor log for Jeffrey Epstein at MCC.
He did not have any visitors other than legal visitors – query whether this can be produced.
(11) Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended.
(12) All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch.
(13) The Post-Watch report compiled in order to take Jeffrey Epstein off suicide watch.
(14) The overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and on July 22 and 23.
(15) Documents showing which staff were augmented at MCC and what positions they worked in on Aug. 9 and 10, and on July 22 and 23.
I do not think we should produce the above, which are subject to the Protective Order, could likely be produced in some fashion after trial, and relate to topics that witnesses will testify about at trial.
(1) The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10. – the sign-in log in the SHU is signed by supervisors when they visit the SHU and does not contain times. Both the log and the 30-minute round forms and count slips are subject to the protective order in the Noel case and should not be produced ahead of trial.
(2) All quarter entries (showing which cells he was housed in) for Jeffrey Epstein at MCC. I don't see why this necessarily needs to be held back; but at the same time I think it's entirely defensible to not produce piecemeal the BOP records related to Epstein prior to trial.
(3) The CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC. I don't believe he had any separates. I don't feel strongly about the CIM clearance.
(4) The chronological disciplinary records for Jeffrey Epstein at MCC. This would only include the 7/23 suicide attempt, which should not be disclosed prior to trial because we may have witnesses testify about it. I would think this could be released after trial.
(5) The intake screening form for Jeffrey Epstein at MCC.
(6) The security designation records for Jeffrey Epstein at MCC.
(7) The inmate profile for Jeffrey Epstein at MCC.
(8) All incident reports related to Jeffrey Epstein at MCC.
(9) All medical reports related to Jeffrey Epstein at MCC.
I do not think we should produce the above, which are subject to the Protective Order, could likely be produced in some fashion after trial, and relate to topics that witnesses will testify about at trial.
(10) The signed visitor log for Jeffrey Epstein at MCC.
He did not have any visitors other than legal visitors – query whether this can be produced.
(11) Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended.
(12) All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch.
(13) The Post-Watch report compiled in order to take Jeffrey Epstein off suicide watch.
(14) The overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and on July 22 and 23.
(15) Documents showing which staff were augmented at MCC and what positions they worked in on Aug. 9 and 10, and on July 22 and 23.
I do not think we should produce the above, which are subject to the Protective Order, could likely be produced in some fashion after trial, and relate to topics that witnesses will testify about at trial.
EFTA00022088
Request #2 (8/13/19)
(1) All video camera footage at MCC pertinent to the Jeffrey Epstein suicide and the first suicide attempt.
(2) All BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt.
(3) All BOP documents, including email correspondence and meeting minutes, pertaining to the decision to remove Jeffrey Epstein from suicide watch.
(4) All BOP special investigation reports mentioning Jeffrey Epstein.
(5) All BOP correspondence with the U.S. Attorney's Office regarding Jeffrey Epstein.
I do not think we should produce the above, which are subject to the Protective Order, could likely be produced in some fashion after trial, and relate to topics that witnesses will testify about at trial.
(1) All video camera footage at MCC pertinent to the Jeffrey Epstein suicide and the first suicide attempt.
(2) All BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt.
(3) All BOP documents, including email correspondence and meeting minutes, pertaining to the decision to remove Jeffrey Epstein from suicide watch.
(4) All BOP special investigation reports mentioning Jeffrey Epstein.
(5) All BOP correspondence with the U.S. Attorney's Office regarding Jeffrey Epstein.
I do not think we should produce the above, which are subject to the Protective Order, could likely be produced in some fashion after trial, and relate to topics that witnesses will testify about at trial.
Request #3 (12/19/19)
(1) The full log of Mr. Epstein's phone calls to and from the MCC. Does not exist.
(2) All email correspondence to and from Mr. Epstein while he was at the MCC (including any correspondence through the Corrlinks system or any other email system he had access to.) Does not exist.
(1) The full log of Mr. Epstein's phone calls to and from the MCC. Does not exist.
(2) All email correspondence to and from Mr. Epstein while he was at the MCC (including any correspondence through the Corrlinks system or any other email system he had access to.) Does not exist.
EFTA00022089
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