Epstein Secrets

8 WL 3956494, at *4-.5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00087767 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

18 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00092433 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

18 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00097970 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

18 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00098811 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

18 WL 3956494, at *4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00099677 Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 8 of 8 Honorable Alison J. Nathan October 7, 2020 Page 8

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

d to the Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), and the Department of Homeland Security. In addition, such information includes information in EFTA00016136 --- PAGE BREAK --- August 1

thers") referenced in ¶ 22 of the indictment. IV. Brady Material A. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitne