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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
hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.5 In particular, during the course of its in
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
hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.' In particular, during the course of its in
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
hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.' In particular, during the course of its in
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
hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.' In particular, during the course of its in
, 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
hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.5 In particular, during the course of its in
Entities connected to both Alison J. Nathan and the Department of Justice's Office of Professional Responsibility

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONJeffrey Pagliuca
PERSON
Audrey Strauss
PERSON
Prince Andrew
PERSON
Michael Cohen
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONSecond Circuit
ORGANIZATIONthe Southern District
LOCATIONFBI
ORGANIZATIONCollins
PERSON
Brady
PERSON
Southern District of New York
ORGANIZATION
Giglio
PERSONEmmy Taylor
PERSON
Supreme Court
ORGANIZATION
Martha Stewart
PERSONThompson
PERSONMark S. Cohen
PERSON