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uring our investigation. To date, our team has not identified any photographs of among those seized. 7 As discussed below, we have identified one FedEx invoice from 2002 reflecting a package sent from Epstein's business address in Manhattan to home address in 2021.01.26 EFTA 00023125 EFTA0273123
led receiving multiple gifts from Epstein. received multiple s of lingerie orm Victoria's Secret, which were shipped to her home by either UPS or FedEx. had a New York address.? She also reca recalls seeing that the return address for these packages s that the packages either had Epstein's or Maxw
s Office. Also consistent with the October 7, 2020 letter, we have taken the following steps to obtain additional agency files to review for Brady, Giglio, and Jencks Act material. First, we have confirmed with the U.S. Attorney's Office in Georgia that it does not possess any substantive witness stat
claims 4 The Government understands from defense counsel that the CD containing a copy of this production, which the Government sent to the MDC via FedEx overnight shipping last week, has not been provided to the defendant. The Government has repeatedly asked MDC legal counsel to locate this CD and p
21. The Government has also agreed to provide notice pursuant to Federal Rule of Evidence 404(b), a proposed witness list, Jencks Act material, and Giglio material 45 days in advance of trial. As a result, the defense will receive many of these disclosures weeks in advance of when is typical for crimi
ion here. See Fed. R. Crim. P. 16(b)(I)(B) & (b)(I)(C). I. AT&T phone records SDNY GM 00514773-00514915 Certification — attached as Exhibit A 2. Federal Express records SDNY GM 00338750-343831 Certification — attached as Exhibit B List of certified invoices (highlighted in yellow) — attached as Exhibit C
ent requests which the defense may want to use in any case-in-chief. Third, the government is still producing Rule 16 discovery, 3500 material, and Giglio material, which may require additional investigation and may, in turn, yield additional documents that the defense may wish to use in any case-in-ch
Entities connected to both FedEx and Giglio

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
Ralph Lauren
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
Richard Kahn
PERSON
Marc Rich
PERSON
David Rodgers
PERSON
George W. Bush
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONLarry Harrison
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Alfredo Rodriguez
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSON