Epstein Secrets

se us promptly whether the government will be producing Brady material immediately even if it is contained in what might otherwise be considered as Jencks material, or whether you take the position that you arc not obligated to produce such material at this time. EFTA00096241 August 1, 2019 Page 11

cluding 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. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests immediate identification and disclosure of all mater

cluding 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. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests immediate identification and disclosure of all mater

se us promptly whether the government will be producing Brady material immediately even if it is contained in what might otherwise be considered as Jencks material, or whether you take the position that you arc not obligated to produce such material at this time. EFTA00016145 --- PAGE BREAK --- Aug

22 specific requests (the "Requests"). The letter also makes a general request for materials pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419 (1995), followed by 10 "specific Brady requests." As an initial matter, we take seriously our disclosure obligations, incl

(S.D.N.Y. Jan. 6, 2010) (declining to order immediate disclosure of Giglio material, because the Government stated it would provide both Giglio and Jencks Act material "shortly before trial"); United States v. Davis, No. 06 Cr. 911 (LBS), 2009 WL 637164, at *14 (S.D.N.Y. March 11, 2009) ("The Second C