Epstein Secrets

U.S. Department of Justice United States Attorney Southern District of New York By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and

fic 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, including those

ober 21, 2020, so that we may file any necessary motions with the Court. Thank you in advance for your attention to these matters. Sincerely, Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: Mark S. Cohen, Esq. Jeff P

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 for, locate, i

ober 21, 2020, so that we may file any necessary motions with the Court. Thank you in advance for your attention to these matters. Sincerely, Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. L

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 for, locate, i

ober 21, 2020, so that we may file any necessary motions with the Court. Thank you in advance for your attention to these matters. Sincerely, Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq. EFTA00066

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 for, locate, i

ober 21, 2020, so that we may file any necessary motions with the Court. Thank you in advance for your attention to these matters. Sincerely, /s/ Christian Everdell cc: EFTA00084870

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 for, locate, i

ober 21, 2020, so that we may file any necessary motions with the Court. Thank you in advance for your attention to these matters. Sincerely, Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. L

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 for, locate, i

ober 21, 2020, so that we may file any necessary motions with the Court. Thank you in advance for your attention to these matters. Sincerely, Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP New York, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C.

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 for, locate, i