Epstein Secrets

for life. Former State Attorney Krischer communicated with Acosta concerning the NPA’s negotiation with Epstein’s lawyers. Appendix at 7; 3 (NPA; OPR Report, p. 81). 38. Epstein was not incarcerated in a Florida prison for the State crimes for which he was convicted. Instead, he was placed in a private wi

ct discs were found with handwritten labels including the descriptions: “Young [Name] + [Name],” “Misc nudes 1,” and “Girl pics nude.” Appendix at 9 (Berman Letter at pp. 1, 9). 50. On July 8, 2019, prosecutors with the Public Corruption Unit ofthe U.S. Attorney’s office for the Southern District of New Y

MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Assistant United States Attorneys - Of Counsel - EFTA00027307 --- PAGE BREAK --- Case 1:

ontention that drafts of the Inspector General's Report itself (and any related work product)—as opposed to the underlying materials upon which the Report is based—are subject to disclosure. To the extent that the forthcoming Inspector General's Report relies on information gathered during the instant

MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Assistant United States Attorneys - Of Counsel - EFTA00031263 --- PAGE BREAK --- TABLE O

has already produced in discovery all of the materials it provided to the DOJ-OIG attorneys preparing the Report, the underlying materials for the Report would be merely cumulative of information in the defendants' possession. Any analysis of those materials by the attorneys preparing the Inspector Ge