EFTA00028448

Document Text

From: Bruce Barke To: Cc: Aida Leisenrin Ton Ricco BRUCE KOFFSK Subject: Re: New mcc problems Date: Fri, 17 Jan 2020 17:07:05 +0000 Thank you for the quick reply. I understand your position regarding communicating with all counsel of record. I assume that means your office won't be having separate communications (written or oral) with just appointed counsel. I. As I indicated, we will be filing a motion asking for an order allowing inspection of the location our client has been detained for what will likely be 4 years by the time the case is tried. Being able to present mitigating evidence to prevent Nick's execution is a "specific and pressing reason," at least in our view. We are happy to work with the BOP on reasonable conditions for the visit. 2. I will wait to hear from her. Thanks for helping to move this alone. 3. Thank you for the update on the hearing situation. I appreciate it. Knowing what the current situation is matters as does being to able to report back to the clients who brought the problem to my attention. 4. This is a bit of a problem. I have been writing these emails since August. I do not think I should have to spell out how a requested visit helps in the preparation of the defense or how it will help our mitigation case. The tension between having a record made justifying the exception a ainst our right not to s ell out the details of our strategy was address back in August during a call that include . At that time we reached a