Epstein Secrets

'Epstein ; Andrew Patel 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

' name on an AEO basis. If I have that right, we will revise the letter. 2. You are agreeing to wait on disclosing this material until after Judge Torres rules on our application. Again, we will revise the letter to reflect that. 3. We will make that modification to the letter that this is a disclosu

Subject: RE: Epstein > 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

la , ' I/ , Andrew Patel Subject: Re: Epstein Date: Fri, 20 Dec 2019 23:41:35 +0000 We will send you a draft before we file the letter to Judge Torres. We will get you a draft ASAP. Have a good weekend. Andy Andrew G. Patel Attorney at Law Sent from my phone > On Dec 20, 2019, at 6:36 PM, a a

ow Subject: RE: pstein 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

Fri, 20 Dec 2019 23:36:40 +0000 Andy, We cannot agree to these redactions, and think it would be appropriate for you to file a motion before Judge Torres, under seal and copying the Government (but ex pane as to the defense). Could you please send us a copy of the letter before you file it, so that we

an AEO, which misstates our intention. 2. When we discussed this, we understood that this would not be submitted to defense counsel prior to Judge Torres ruling on your request. There is no language in the letter to that effect, and it seems appropriate to add it. 3. Please add "to the defense" in the

nnella I>; Andrew Patel 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