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e the disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your eff
Page: EFTA00027031 →From: To: Andrew Patel -"Ma Cc: Jill Shellow MEW, Don Yannella Subject: RE: Epstein Date: Fri, 20 Dec 2019 22:56:20 +0000 Thanks Andy, we will review and get back to you early next week. Original Message F
Page: EFTA00027031 →2 mentions1 same-page
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e the disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your eff
From: Andrew Patel To: (USANYS)" Cc: Jill Shellow Don Yannella '1 11 Subject: Re: Epstein Date: Thu, 26 Dec 2019 14:07:37 +0000 Just to be clear. 1. Your Ian Ian is to turn over the redacted notes to the d
2 mentions1 same-page
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re. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not EFTA00100324 believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your eff
From: Andrew Patel <Ma To: 'Pa" Cc: Jill Shellow Don Yannella , ' 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 To
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2 mentions1 same-page
Page ?Same page
e the disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your eff
From: na ll To: Andrew Patel 4IMIlle Cc: Jill Shellow , Don Yannella , " 11 Subject: RE: Epstein Date: Fri, 20 Dec 2019 23:36:40 +0000 Andy, We cannot agree to these redactions, and think it would be appropriate
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