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& SEPLOWITZ LLc ATTORNEYS AT LAW PAGE 2 6. The email referenced in Employee Number 7's witness statement that was sent to MCC employees regarding Jeffrey Epstein's need for a cellmate. 7. Psychology Services post-suicide watch report drafted by Employee Number 12 on July 24, 2019. 8. A copy of the memorandum
s, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums d
, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memora
ent, Number I.S. NYM 5500.13, referenced in bates number SDNY 0005392. 13.An unredacted copy of SDNY 7551. 14.An unredacted copy of SDNY 883. 15. SHU Watch Call Logs from August 9, 2019 and August 10, 2019. 16.All SHU Watch Call Logs completed during Defendant Noel's assignment to the SHU post which be
& SEPLOWITZ LLc ATTORNEYS AT LAW PAGE 2 6. The email referenced in Employee Number 7's witness statement that was sent to MCC employees regarding Jeffrey Epstein's need for a cellmate. 7. Psychology Services post-suicide watch report drafted by Employee Number 12 on July 24, 2019. 8. A copy of the memorandum
s, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums d
, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memora
ent, Number I.S. NYM 5500.13, referenced in bates number SDNY 0005392. 13.An unredacted copy of SDNY 7551. 14.An unredacted copy of SDNY 883. 15. SHU Watch Call Logs from August 9, 2019 and August 10, 2019. 16.All SHU Watch Call Logs completed during Defendant Noel's assignment to the SHU post which be
& SEPLOWITZ LLc ATTORNEYS AT LAW PAGE 2 6. The email referenced in Employee Number 7's witness statement that was sent to MCC employees regarding Jeffrey Epstein's need for a cellmate. 7. Psychology Services post-suicide watch report drafted by Employee Number 12 on July 24, 2019. 8. A copy of the memorandum
s, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums d
, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memora
ent, Number I.S. NYM 5500.13, referenced in bates number SDNY 0005392. 13.An unredacted copy of SDNY 7551. 14.An unredacted copy of SDNY 883. 15. SHU Watch Call Logs from August 9, 2019 and August 10, 2019. 16.All SHU Watch Call Logs completed during Defendant Noel's assignment to the SHU post which be
you and fam have been well, as well as MCC staff. EFTA00030480 --- PAGE BREAK --- Can you please provide the following information concerning the Epstein suicide investigation: • The BOP and MCC Employee Code of Conduct, Code of Ethics, and corresponding employee acknowledgement forms for Defendant N
Page: EFTA00030481 →spections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13. • SHU Watch Call Logs from August 9, 2019 and August 10, 2019. • All SHU Watch Call Logs completed during Defendant assignment to the SHU post which began on June 26, 2019. • All SHU Control Center Logs completed during Defen
Page: EFTA00030481 →tline. 4. The MCC annual training outline for 2018 and 2019. 5. A copy of the internal memorandums, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums drafted by Employee Number 5, Employee Number 6, and Employee Number 13. EFTA00023768 --- PAGE BR
Page: EFTA00023768 →2. 13.An unredacted copy of SDNY 7551. 14.An unredacted copy of SDNY 883. 15. SHU Watch Call Logs from August 9, 2019 and August 10, 2019. 16.All SHU Watch Call Logs completed during Defendant Noel's assignment to the SHU post which began on June 26, 2019. 17.All SHU Control Center Logs completed durin
Page: EFTA00023769 →23769 --- PAGE BREAK --- FOY & SEPLOWITZ LLC ATTORNEYS AT LAW PAGE 3 27.A copy of the After Action Internal Report completed after the death of Jeffrey Epstein and Board of Inquiry Report. 28.A copy of the Suicide Reconstruction Report 29.All MCC Correctional Services, Operational Reviews, and Progr
Page: EFTA00023770 →-- PAGE BREAK --- FOY & SEPLOWITZ LLC ATTORNEYS AT LAW PAGE 3 27.A copy of the After Action Internal Report completed after the death of Jeffrey Epstein and Board of Inquiry Report. 28.A copy of the Suicide Reconstruction Report 29.All MCC Correctional Services, Operational Reviews, and Program Revi
Page: EFTA00023770 →to SHU. SROs, assuming they were completed, would then be printed and filed in the inmate's central file. I am currently trying to figure out where Epstein's file is to see if any SROs are in it. If you really want ALL SROs for the period of assignment to SHU, that will be an extremely lengthy process
Page: EFTA00030778 →spections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13. • SHU Watch Call Logs from August 9, 2019 and August 10, 2019. • All SHU Watch Call Logs completed during Defendant assignment to the SHU post which began on June 26, 2019. • All SHU Control Center Logs completed during Defen
Page: EFTA00030780 →t for all SROs during the time of assignment to the SHU, that seems excessively burdensome. Rather, if possible, can you locate the SROs related to Epstein only? The head of the records department at MCC, who is Case Management Coordinator Schnahider Demosthenes reported the central file for Epstein wa
Page: EFTA00032572 →ement/Program Statement, Number I.S. NYM 5511.08. • The Security Inspections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13. • SHU Watch Call Logs from August 9, 2019 and August 10, 2019. • All SHU Watch Call Logs completed during Defendant assignment to the SHU post which began on J
Page: EFTA00032576 →Entities connected to both Jeffrey Epstein and SHU Watch

Prince Andrew
PERSONTova Noel
PERSONLee Plourde
PERSONHACKENSACK
LOCATIONFLETC
ORGANIZATIONFOY & SEPLOWITZ LLC
ORGANIZATIONSHU Control Center
ORGANIZATIONSHU Watch Call Logs
ORGANIZATIONJASON E. FOY
PERSONJamel Floyd
PERSON
Kenneth Houck
PERSONthe Suicide Reconstruction Report
ORGANIZATIONBoard of Inquiry Report
ORGANIZATIONMCC Correctional Services
ORGANIZATIONSHU Operations Lieutenant
ORGANIZATIONInstitutional Supplement
ORGANIZATIONProgram Reviews
ORGANIZATIONthe MCC SHU
ORGANIZATIONOperational Reviews
ORGANIZATIONa. Individual
ORGANIZATION