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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
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
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
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
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
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
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
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
, 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
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
Entities connected to both Alison J. Nathan and Finnerty

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONJeffrey Pagliuca
PERSON
Audrey Strauss
PERSON
Prince Andrew
PERSON
New York City Police Department
ORGANIZATION
Department of Justice
ORGANIZATIONSecond Circuit
ORGANIZATION
United States
LOCATION
Denver
LOCATION
Colorado
LOCATIONthe Southern District
LOCATIONFBI
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONCollins
PERSON
Brady
PERSON
Giglio
PERSON
Martha Stewart
PERSON
Alfredo Rodriguez
PERSONMiddendorf
PERSON