Epstein Secrets

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

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

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

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

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

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

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

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

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

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

other documents that purport to reflect, relate, or incorporate any statements made by Mr. Epstein. ' Such entities include but are nut limited to the New York Police Department, Manhattan District Attorney's Office, State Attorney's Office for the 15th Judicial District in and for Palm Beach County, the Palm Beach County S

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