Epstein Secrets

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

ion of knowledge to the prosecutor . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer the prosecutors' knowledge simply because some other government agents knew about" additiona

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

on of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer the prosecutors' knowledge simply because some other government agents knew about" additiona

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

on of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer the prosecutors' knowledge simply because some other government agents knew about" additiona

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

on of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer the prosecutors' knowledge simply because some other government agents knew about" additiona

, 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

on of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer the prosecutors' knowledge simply because some other government agents knew about" additiona