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ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu
he Government becomes aware of any Brady material from any source, it will promptly disclose such material to the defense. EFTA00087762 Honorable Alison J. Nathan October 7, 2020 Page 3 to persons who are a part of the `prosecution team' . . . who perform investigative duties or make strategic decisions abo
ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu
lications, financial records, travel records, property records, phone records, law enforcement reports, and other subpoena EFTA00092427 Honorable Alison J. Nathan October 7, 2020 Page 2 returns. The Government is continuing the process of reviewing and preparing productions of electronic discovery materials
ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu
he Government becomes aware of any Brady material from any source, it will promptly disclose such material to the defense. EFTA00097965 Honorable Alison J. Nathan October 7, 2020 Page 3 to persons who are a part of the `prosecution team' . . . who perform investigative duties or make strategic decisions abo
ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu
t of prosecutorial strategy, or (5) accompanied the prosecution to court proceedings." Middendorf, 2018 WL 3956494, at *4. EFTA00098807 Honorable Alison J. Nathan October 7, 2020 Page 4 III. The Government's Plan to Review Certain Files from the Florida Investigation A. Relevant Background Regarding the Fl
ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu
, phone records, law enforcement reports, and other subpoena EFTA00099671 Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 2 of 8 Honorable Alison J. Nathan October 7, 2020 Page 2 returns. The Government is continuing the process of reviewing and preparing productions of electronic discovery materials
Entities connected to both the New York Police Department and Alison J. Nathan

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Prince Andrew
PERSONJeffrey Pagliuca
PERSON
Audrey Strauss
PERSON
Marc Rich
PERSON
New Hampshire
LOCATION
Department of Justice
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
Michael Cohen
PERSON
New York
LOCATIONFBI
ORGANIZATION
Donald Trump
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATION
George W. Bush
PERSON
David Boies
PERSON