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etter of August 21, 2020. 16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part of the investigation conducted by the Southern District of Florida. See SDNY GM 00131226. 17. We request all e-mails, text messages, letters, or other written communications to or from Ms. Maxwell. 18.
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
etter of August 21, 2020. 16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part of the investigation conducted by the Southern District of Florida. See SDNY GM 00131226. 17. We request all e-mails, text messages, letters, or other written communications to or from Ms. Maxwell. 18.
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
etter of August 21, 2020. 16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part of the investigation conducted by the Southern District of Florida. See SDNY GM 00131226. 17. We request all e-mails, text messages, letters, or other written communications to or from Ms. Maxwell. 18.
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
mplex federal and state felony indictments (1976-present) Panel member, Federal Criminal Justice Act Panel in the United States District Court for the Southern District of New York (1985-1992) Panel member, Homicide, Felony, and Appellate panels, First Department, New York State Supreme Court (1976-present) Assist
2 U.S. Congress, House Judiciary Subcommittee (July 27, 2000) (Testimony on H.R. 4015: Fair Justice Act of 2000)(testimony) State of Louisiana v. Kyles (October 31, 1997)(testimony) State of Connecticut v. Valentin (March, 1995)(testimony) Commonwealth of Kentucky v. Davidson (April, 1992)(testimon
etter of August 21, 2020. 16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part of the investigation conducted by the Southern District of Florida. See SDNY GM 00131226. 17. We request all e-mails, text messages, letters, or other written communications to or from Ms. Maxwell. 18.
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
etter of August 21, 2020. 16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part of the investigation conducted by the Southern District of Florida. See SDNY GM 00131226. 17. We request all e-mails, text messages, letters, or other written communications to or from Ms. Maxwell. 18.
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
etter of August 21, 2020. 16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part of the investigation conducted by the Southern District of Florida. See SDNY GM 00131226. 17. We request all e-mails, text messages, letters, or other written communications to or from Ms. Maxwell. 18.
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
but not limited to communications with the United States Attorney's Offices for the Northern District of Georgia, Southern District of Florida, and the Southern District of New York. EFTA00096236 August 1, 2019 Page 6 Steptoe SIDON & JOHNSON LIP 27. Relating to any investigation undertaken by the Department o
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
Entities connected to both the Southern District and Kyles

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Prince Andrew
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
Geoffrey S. Berman
PERSON
Southern District of New York
ORGANIZATION
Paul Cassell
PERSONMartin Weinberg
PERSON
Alfredo Rodriguez
PERSON
Joe Biden
PERSON
Michael Cohen
PERSON
Supreme Court
ORGANIZATION
David Boies
PERSON
Lesley Groff
PERSONFederal Bureau of Prisons
ORGANIZATION