Epstein Secrets

t initial production is nonsense. As the Court is aware, the EFTA00040543 Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 2 of 5 Honorable Alison J. Nathan August 13, 2020 Page 2 protective order was docketed on Friday, July 31, 2020'—the timing of which was principally the result of the defendant's

or, in this case, the BOP. The Government learned of the defendant's specific objections to her conditions of incarceration for the first time from the Defense Letter, and has since conferred with BOP to understand and to address the issues as appropriate. Moreover, as noted below, the defendant filed the instant

ive order and initial discovery, to facilitate the production EFTA00075314 Case 1:20-cr-00330-AJN Document 9 Filed 07/07/20 Page 2 of 2 Honorable Alison J. Nathan July 7, 2020 Page 2 of discovery, which will serve the interests of justice by facilitating the timely production of discovery materials. See 18

8). Pursuant to the Order, the parties have conferred regarding the scheduling of an initial proceeding in the above-captioned case. As set forth in the Defense Letter, the parties are available to proceed remotely on the morning of July 14, 2020. Additionally, the parties jointly respectfully propose the followin

legal arguments—more than four months in advance of the deadline for any such motion—relating to the ages of the victims. EFTA00077274 Honorable Alison J. Nathan August 13, 2020 Page 3 ordered disclosure of a certain victim identity shortly after the indictment, the Court noted that the Government had alre

or, in this case, the BOP. The Government learned of the defendant's specific objections to her conditions of incarceration for the first time from the Defense Letter, and has since conferred with BOP to understand and to address the issues as appropriate. Moreover, as noted below, the defendant filed the instant

t initial production is nonsense. As the Court is aware, the EFTA00084837 Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 2 of 5 Honorable Alison J. Nathan August 13, 2020 Page 2 protective order was docketed on Friday, July 31, 2020'—the timing of which was principally the result of the defendant's

or, in this case, the BOP. The Government learned of the defendant's specific objections to her conditions of incarceration for the first time from the Defense Letter, and has since conferred with BOP to understand and to address the issues as appropriate. Moreover, as noted below, the defendant filed the instant