6
Shared Docs
5
Same-Page
6 / 6
Mentions
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
ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi
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
ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi
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
ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi
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
ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi
, 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
ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi
d, in August, after the defendant sought an order directing the Government to disclose to defense counsel the identifies of the Minor Victims, Judge Nathan ruled that the request was premature, noting that production of discovery had just begun and the "parties have not yet engaged in discussions regar
Page: EFTA00030572 →estigation and prosecution of Jeffrey Epstein, as set forth in greater detail in that letter, the Government intends to gather certain martials from USAO-SDFL and conduct targeted searches of that material aimed at identifying potential Giglio or 3500 material for victims or witnesses relevant to this pro
Page: EFTA00030573 →Entities connected to both Alison J. Nathan and USAO-SDFL

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONJeffrey Pagliuca
PERSON
Audrey Strauss
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONLaura Menninger
PERSON
New Hampshire
LOCATION
Michael Cohen
PERSONBobbi C. Sternheim
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONDistrict Court for the Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATION
Christian Everdell
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Colorado
LOCATION
Denver
LOCATIONEmmy Taylor
PERSON