Epstein Secrets

: •c > Sent: Sunday, August 02, 2020 14:49 To: Subject: Fwd: Jeffrey Epstein-Related Touhy Requests With this in mind, could you please save the Touhy correspondence in the 3500 folder? Thanks. Sent from my iPhone Begin forwarded message: From: "a (USANYS)" • Date: Au ust 2 2020 at 2:30:39 PM E

view that the fact of production of materials is Giglio? Or that the substance of her attorney's request and the government's responsive letter is Giglio? Just want to make sure we understand the theory. thanks, From: S (USANYS) Sent: Sunday, August 02, 2020 13:44 To: ) < ;'; Cc: (USANYS) < (U

Epstein-Related Touhy Requests (USANYS) < ; BTW, I probably don't need to tell you, our Touhy communications with El are probably disclosable as Giglio info. From: (USANYS) < Sent: Tuesday, July 28, 2020 5:32 PM To: (USANYS) < Cc: (USANYS) < >; Subject: RE: Jeffrey Epstein-Related Touhy Requ

oday. As for the size of the hard drive for 3500 materials, we think a drive of 64GB should work. We will let you know if that changes. As for the Touhy request, we are in the process of getting in touch with the individuals you identified in your letter to confirm their availability and discuss logi

. As we discussed, we will expect to receive all the materials that are due on Oct. 11 on the day of the deadline. That includes the 3500 material, Giglio material, 404(b) notice and evidence, co-conspirator identities and statements, the government's witness list, and the government's exhibit list. W

ert testimony. The Government has moved to preclude the defense from offering such evidence, including by calling the case agents identified in its Touhy notice. (See Gov't Motions in Limine Section III). Accordingly, if the defense plans to call case agents for such testimony—which the Court should p

(Id.) On June 2, 2021, the Court adopted the "Government's proposal" and set a deadline of October 11, 2021, for the "disclosure of Jencks Act and Giglio material, Rule 404(b) evidence and 56 EFTA00088858 notice, co-conspirator statements, and Government witness list," as well as the "Defendant's

From: Sent: Sunday, August 02, 2020 14:49 To: Subject: Fwd: Jeffrey Epstein-Related Touhy Requests With this in mind, could you please save the Touhy correspondence in the 3500 folder? Thanks. Sent from my iPhone Begin forwarded message: From: "McEnany, John (USANYS)" Date: Au ust 2 2020 at 2:3

view that the fact of production of materials is Giglio? Or that the substance of her attorney's request and the government's responsive letter is Giglio? Just want to make sure we understand the theory. thanks, Alex. EFTA00088120

' y, To:' Subject: Fwd: Jeffrey Epstein-Related Touhy Requests Date: Sun, 02 Aug 2020 18:48:38 +0000 With this in mind, could you please save the Touhy correspondence in the 3500 folder? Thanks. Sent from my iPhone Begin forwarded message: From: "McEnany, John (USANYS)" Date: August 2. 2020 at 2:

view that the fact of production of materials is Giglio? Or that the substance of her attorney's request and the government's responsive letter is Giglio? Just want to make sure we understand the theory. thanks, Alex. From: McEnany, John (USANYS) Sent: Sunday, August 02, 2020 13:44 To: <En Cc: J

ar, Steven (USANYSY Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Sun, 02 Aug 2020 18:30:39 +0000 1=a (USANYS)" Determinations under Touhy are somewhat discretionary and to the extent our Office exercised discretion to give the W something the W wanted, that could be construed as a bene

r view that the fact of production of materials is Giglio? Or that the substance of her attorney's request and the government's responsive letter is Giglio? Just want to make sure we understand the theory. thanks, Alex. From: McEnany, John (USANYS) Sent: Sunday, August 02, 2020 13:44 To: Cc: Jones