From: NYS)" To: ANY Cc: Subject: RE: viewing tartaglione cell Sent: Mon, 2 Dec 2019 16:07:29 +0000 I'm back in the office and around to discuss this week at your convenience, Hope you had a nice holiday. • From: (USANYS) c > Sent: Wednesda November 27, 2019 11:36 AM To: Cc: Subject: RE: viewing tartaglione cell Thanks for your email and good wishes. I believe that is out of the office until next week. Can this wait until then? I hope that you too have a Happy Thanksgiving. Take care, U Chief, Civil Division U.S. Attorney's Office, SDNY 86 Chambers Street, 3'd Floor New York, NY 10007 From: Sent: Wednesda November 27, 2019 11:23 AM To: (USANYS) Cc: Subject: Fwd: viewing tartaglione cell Hi M, We may need wall counsel again in the Tartaglione matter in relation to the below site visit request. so excellently helped us last time in our appearance on the conditions of confinement issue, so I cc'ed her as well. Thank you and I wish you and yours a Happy Thanksgiving. Best Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 p: EFTA00043902

f: >> > Bruce Barket < > 11/27/2019 11:15 AM >> > As part of our obligations to prepare for the penalty phase (should there be one) of Mr. Tartaglione's trial, we would like to view the cells (including SHU ) and common areas where he has been held. It's possible that we will want to take some photographs, but initially we just want to look at the areas where he has been housed. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden Cit , NY 11530 [Pi [F] 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 EFTA00043903

Re: Fed: counsel tuning difficult) meeting with client From - lo Date 2019/07/07 21:45 Subject: Re: Fwd: counsel having difficulty meeting with client .tttachmenta: TEXT.htm Thanks. Sent Mom my Vefizon, Samsung Galaxy unattplione • in tiol e .c From Date 7/7/19 8.49 PM GMT-05. To: -< > Subject Re Fwd counsel having difficulty meeting with diem >>> 07/07/20192049 >>> Copy. I mil pass the information to the lieutenants. Jermarne C. Captain Metropolitan Correctional Center 150 Park Row New York NY 10007 Office (646)836-6448 Blackberry (646)423-0779 >> > > 7/7/2019 6:58 PM >> Sent from my Vertion. Samsung Galaxy scnaitphone Front Subject: Fwd: cocked having difficulty meeting with diet aitalrriessacA ">> "M=" 07/07/201918:22 »> I have verified Martin Weinberg Han attorney in good standing in Massachusetts. He is pemtitted to visit Jeffrey Epstein.Sent from my Venzon. Samsung Galaxy smanphoi </div> cdiv> <MN> <!-- ofiginSMessage --><div> Original message </div> <div>From .e l.> <Mkt> </dal> >>> Or O 07/07/20191878 > » Massachusetts Front < > Sentiallit To: Subject: Re counsel having difficulty meeting with dient Sony. just seeing this now. Where is he barred? Sent from my Vernon Samsung Galaxy smartphone nt Ori ina s From " RIPI10:a Data6PM(GtiAl To MIM4. .mailto.la Subject: RE: counsel having difficulty meeting with client main° >>> r 07/07/201917:36 > > > Page 13393 EFTA00043904

With apologies for the weekend email, we have a defendant. Jeffrey Epstein, who was arrested last night and is currently being detained at MCC, and is expected to be ins of-state Were concerned about the defendant not having access to his attorney in advance of the presentment (as we would be for any defendant) and so I wanted to reach out to thanks very much, U Page 13394 EFTA00043905

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Re: Fed: counsel basing difficult) meeting with client From To Date 2019/07/07 20:49 Subject: Re: Fwd: counsel having difficulty meeting with client Attachments: TEXT.htm Page 13397 EFTA00043908

Copy, I will pass the information to the lieutenants lermame C. Captain Metropolitan Correctional Center 150 Park Row New York, NY 10007 Office (646) 836-6448 Blackberry (646)423-0779 >>> > 7/7/2019 6:58 PM »> Sent horn my Vernon Samsung Galaxy smanpnone Fro a linamesas a nt Date: 70/19 622 PM (GMT-05:001 To: < > Subject: Fwd: counsel having difficulty meeting wth client >>> 07/07/2019 18:22 »> I have verified Martin Weinberg is an attorney in good standing in Massachusetts. He is permitted to visit Jeffrey Epstein.Sent from my Verizort Samsung Galaxy smartpho </drv> sdiv> </dile> <!-- originalMessage --> <div> Original message <idly> <thy >From <Idly> » > 07/07/2019 18:18 » Massachusetts Front Sent . Jul 07. 2019 1&18 To: < >:a Subject Re. counsel having difficulty meeting with diets Sony.. just seeing this now. Where is he barred> Sent from my %Mixon. Samsung Galaxy smanphone Qi ir i Front < rnailtcr Date: 70/19 5.36 PM (GMT-05:00) To: crtmilto:[email protected]> > Subject. RE: counsel having difficulty meeting with client > > > "07/07/2019 17:36 > » 'Mr" With apologies for the weekend email, we have a defendant, Jeffrey Epsteirt who was arrested last night and is currently being detained at MCC, and is expected to be pres of-state Were concerned about the defendant not having access to his attorney in advance of the presentment (as we would be for any defendant) and so I wanted to reach out to thanks very much, Page 13398 EFTA00043909

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Fwd: RE: Tartaglione From To Date 2019/07/22 21:38 Subject: Fwd: RE: Tartaglione Attachments: TEXT.htm I intend for him to be the first patient I see tomorrow morning. Thanks. >>> Ml 7/22/2019 10:43 AM > » D Hi, I wrote about this last week and I know he intended on seeing him. Psy.D. Chief Psychologist U.S. Department of Justice/ Federal Bureau of Prisons Metropolitan Correctional Center 150 Park Row New York, New York 10007 Office: Fax: E-mail: >> > 7/19/2019 9:25 AM >>> Can you please have him seen for his request for 7 I understand he has not expressed an, concerns in the past, but he is facing the death penalty and is currently in SHU facing disciplinary c rges. Thanks! Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 p: > » Bruce Barket < Good morning, > 7/19/2019 6:39 AM > » I was able to see Nick last night. Thank you for arranging a room for him. He reports that he has not had his hearing yet and the conditions in his cell remain the same. He was told by a guard that he is going to be denied visits, phone calls and commissary for a year, in addition to being held in SHU for 90 days. Water is constantly leaking into the cell, which he now shares with another inmate. He still has not received the updated discovery hard drive. He has only been given three short books which he rerael taut:sral tirnae dacnitcs Ivauinn nwat knnlec <ant in him haul hones tines resraintt inrlir,fines tk,t nnrr k.ae Page 13401 EFTA00043912

1 1/4.44 O,1..V 1/4.14.111 4.1181‘..J, 8.1....11.08.A. 884V8185 8 8 1/4. nr 8".“01"...8 O...Ill %Ad 81818I 1YVI. 114Y1. til 1/4 . I ,...‘ 1/4.8t.“..) III41l.4llll5111411V11.1. 114J received them). He does not have the paper discovery he had prior to being placed in SHU. Recently, he found a dead rodent in his bed. Apparently he accidently smothered it while sleeping. The lights in the cell are frequently off during the day and on at night. I understand that the cell phone justifies some sanction, but the troubling conditions in the cell should be rectified. Lastly, I hope the guard who told Nick about his punishment is mistaken. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden Cit , NY 11530 [P] [F] 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 From: Sent: Monday, July 15, 2019 3:48 PM To: Bruce Bark • Cc: tonyricco ; Aida Leisenring; [mailto Subject: Re: Tartaglione Bruce, My apologies for the delay yesterday. The institution was short-staffed, and they were actively finding personnel to process you in the lobby and to oversee the attorney conference room area. If you experience any delays on the weekends, please ask to speak to the Duty Officer and/or the Operations Lieutenant as they were aware of the visit and could have expedited your admission to the facility. They also could have called me at home to resolve any issues. Likewise, if ou are visiting during the week and we have made arrangements to expedite your visits, please contact and me if there are any delays so we can facilitate matters immediately. Please also let us know when you meet in an attorney conference room that has a non-working computer so that we can have Computer Services fix it expeditiously. We continue to work to address Mr. Tartaglione's complaints, so please let us know if there are outstanding issues that have not yet been appropriately addressed. Thank you, > » Bruce Barket < > 7/14/2019 11:55 AM > » While I do appreciate your effort, for reasons that aren't entirely clear to me, the personal seem unable to allow Nick reasonable access to his lawyers. Page 13402 EFTA00043913

Today, I arrived at the faculty at 7:56. I was told "not until 8:00" by the guard in the booth. At 8:00 I was told "we will let you know. We are waiting for relief." I waited outside for 35 minutes. (I am lucky to be healthy, as I was forced to stand because the waiting area was inexplicably locked). I finally got to see Nick just after 9:00, less than 30 minutes before the cut off to leave before the count. Unfortunately, this is not a recent problem. Long delays, unexpected closures of the facility and lockdowns have all occurred frequently since Mr. Tartaglione was first arrested, over 3 years ago and have significantly hampered our ability to communicate with our client, who is facing the death penalty. Because the BOP has chosen to monitor emails and phone calls between Lawyers and their clients, we are forced to meet with Nick to discuss every aspect of the case, even relatively benign things that typically could be handled with a quick call or a short email. As you know, I have been writing about these problems, speaking to you and bringing the issues to the attention of Judge Karas over the course of the years of Nick's Pretrial detention. On a personal note, this was a particularly frustrating day because I again took time away from my family on a Sunday to drive into NYC with anticipation that would be able to leave at 9:30. Today's trip, as you know, was necessary because Ms. Leisenring and I arrived on Thursday at 7:55 but were not permitted to see our client until 9:30. These obstacles to meeting with our client are systemic and do not appear to be correctable without significant changes in how the BOP operates the faculty. The rooms for visiting have computers that are frequently broken, there are not enough rooms to accommodate the number of lawyers attempting to see their clients (several hours of delays are routine for any lawyer who doesn't arrive before 8:00), the staff frequently delays the opening of legal visiting but never extends the closing time, once in a room, a lawyer can expect to wait for their client to be produced from 10-15 minutes to hours and of course at times the facility simply closes and refuses visits all together. The USA's office has advised that the Marshal's have refused our request to transfer Mr. Tartaglione to Nassau County and despite my inquiry about other options, have not offered any alternative. The conditions under which Mr. Tartaglione Are being held continue to be problematic, to say the least. There is again water in his cell and the other issues, which I have written about a number of times but won't detail again here, persist. I don't think anyone understands what it is like to be locked in a windowless box all day, everyday with limited human contact and virtually no contact with family or friends. People can't survive like that for very long. Cell phone or not, the conditions in SHU are deplorable. Discussing the issues surrounding his complex death penalty case has become nearly impossible. Whether intentional or accidental, the MCC is breaking Mr. Tartaglione's ability to defend the charges and prepare for trial. I am open to any solution Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden Cit , NY 11530 -O ,cu JR7 7)Qr1 - Page 13403 EFTA00043914