Good morning all, Would 2 or 2:30 work? I am running around this morning, have a meeting at I. and am leaving at 3. Thanks, >» " < > 8/29/2019 7:54 PM >>> Received. would you all be free for a call tomorrow afternoon to discuss? Thanks, Assistant United States Attorney Southern District of New York New York, NY 10007 From: Bruce Barket Sent: Thursda August 29, 2019 5:25 PM To: Cc: Michael Bachrach Subject: MCC conditions I am writing as I have been asked to update everyone on the continuing problems at the facility. Mr. Tartaglione has not has books swapped out since was kind enough to it himself on August 151h. His radio has needed batteries for several days. The guards simply refuse to provide him with the batteries and new books he believes are in his property. Several guards have been making comments to him such as "You're threatening our lives" and "Give the big mouth his try" and similar remarks aimed at intimidating him and conveying to him their displeasure with his complaints. As for visiting I arrived on Sunday and waited nearly 50 minutes because there was not staff in the lobby to process legal visits. I was able to see my client by 9;10, but I couldn't stay through the count so I had to leave before 9:30. I know I did not make an appointment but the issue wasn't a free room, but adequate staffing in the lobby. Yesterday I was able to see my client at 5:00 as scheduled. Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 (P) (516) 745 1245 (Fl SDNY_00016735 Page 133 EFTA00138645

RE: update on social visit? From To Date Subject: Attachments: Bruce Barket 2019/08/29 17:18 RE: update on social visit? TEXT.htin, Mime.822 I am sorry, but that won't be sufficient. We had a conversation with back and they told us that, in light of the particular needs for preparation for a capital case, MCC would permit periodic social visits as needed. I did not raise this issue with the court because of what we were told. Perhaps I misunderstood. and a few weeks Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [P1 (516) 745 1245 [F] 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: Thursday, August 29, 2019 3:03 PM To: Bruce Barket Cc: r Subject: RE: update on social visit? Hi Bruce, After some discussion, MCC's administrators are prepared to offer your client a social phone call with his parents, which would be outside the normal phone schedule provided to inmates in Special Housing. If you fell that would be inadequate, please advise and and I will take the issue back to our administrator& ar m ( ou, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 SONY_00016736 Page 11158 Pace 134 EFTA00138646

>> > 8/28/2019 4:23 PM > » Hi Bruce, Our Exec staff are still discussing it. I should hopefully have an answer for you by tomorrow. In the meantime, can you give me any information about the "critical stage" in the case? I don't want to know anything that would violate privilege, but something very general (e.g. a plea is on the table, a cooperation agreement is on the table, etc.) might help our Exec staff evaluate the request. Thanks, Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 > » Bruce Barket < > 8/28/2019 3:40 PM > » Is there any update on a visit with his parents this week? Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 [P] (516) 745 1245 [F] 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: Wednesday, August 28, 2019 8:31 AM To: Cc: Subject: Re: meeting with Tartaglione No problem - I'll pull him down before the count. Thanks, SDNY_00016737 Page 11159 Pace 135 EFTA00138647

Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, NY 10007 p: f: 646-836-7665 > » Bruce Barket < > 8/28/2019 8:28 AM > » I know it is late notice but I am hoping to see Nick tonight at 5:00. Thank you Bruce A. Barket, Esq. Barket Epstein Kea ron Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 (516) 745 1500 (PI (516) 745 1245 [F] 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 SONY_00016738 Page 11160 Pace 136 EFTA00138648