EPSTEIN
page 6 / 524 . OCR, unverified
file the documents with any reference to evidence/discovery and cooperators redacted? We can then review the
unredacted version and discuss what, if anything, can be unredacted for the public version.
Assistant United States Attorney
From:
Sent: Friday, August 2, 2019 11:03 AM
To:
Cc:
>
(USANYS)
Subject: motions under seal?
Our motions will be ready to go out in a few hours., One is straight forward legal argument about the cell tower data,
which we don't have a problem filing. The other motion deals with the statements to the police and by necessity we
discuss the statements in detail. We also discuss some of the discovery and the cooperating witnesses. What is the
Government position about filing that motion under seal?
Also,
affidavit hasn't been signed because the only regular access to a notary are members of his legal team and we
don't want to witness his signature. We will have him sign it through whatever the process is at MCC or in open court at
our next appearance.
Garden City, NY 11530
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
EFTA00021533
##############################
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METADATA_FILENAME: EFTA00021534.pdf
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From: "=.1,
(USANYS)"
To:
"
Cc:
Subject: RE: motions under seal?
Date: Fri, 02 Aug 2019 15:26:25 +0000
It
=
It is a little difficult to know what needs to be sealed/redacted in the abstract. Out of an abundance of caution, can you
file the documents with any reference to evidence/discovery and cooperators redacted? We can then review the
unredacted version and discuss what, if anything, can be unredacted for the public version.
U.
Assistant United States Attorney
From:
Sent: Friday, August 2, 201911:03 AM
To:
)
Cc
(USANYS)
Subject: motions under seal?
Our motions will be ready to go out in a few hours., One is straight forward legal argument about the cell tower data,
which we don't have a problem filing. The other motion deals with the statements to the police and by necessity we
discuss the statements in detail. We also discuss some of the discovery and the cooperating witnesses. What is the
Government position about filing that motion under seal?
Also,
affidavit hasn't been signed because the only regular access to a notary are members of his legal team and we
don't want to witness his signature. We will have him sign it through whatever the process is at MCC or in open court at
our next appearance.
Garden City, NY 11530
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
EFTA00021534
--- PAGE 2 ---
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METADATA_FILENAME: EFTA00021536.pdf
----------------------------------------
From: '
To: '■
Cc: '
Subject: Re:
)" <
- Epstein
Date: Fri, 02 Aug 2019 13:51:03 +0000
>
>
Agree
On Aug 2, 2019, at 9:39 AM,
Agree
Sent from my iPhone
On Aug 2, 2019, at 09:12,
I think our respons
wrote:
wrote:
But let me know if you disagree.
From: Joe Nascimento c
>
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
Subject: Re:
I
HIM,
<
- Epstein
.t
>
I do not have any travel plans during the month of August, nor does
September is a busy month with two
trials set, and I will be traveling out of the country from Sept 17-30, but I will do everything to be as flexible as
possible.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
13-
f.
EFTA00021536
--- PAGE 2 ---
e.
www.crimlawfirm.com
From: "
<
Date: Thursday, August 1. 2019 at 6: 10 I'M
To: Joe Nascimento <
Cc: '
Subject: RE:
) - Epstein
Joe,
As we start thinking about scheduling a next meeting witha
we were wondering if you could please let us
know if there are any particular weeks that would not work for you or your client for a meeting in Florida (in particular,
we don't want to interfere with anyone's summer vacation plans).