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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
pecialist to provide the Prosecution Team with a copy of the files still in PBPD's possession related to the Florida Investigation. In response, the PBPD Records Specialist provided the Government with 60 pages of documents, which the Prosecution Team reviewed for any material that is non-duplicative and warrants discl
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
pecialist to provide the Prosecution Team with a copy of the files still in PBPD's possession related to the Florida Investigation. In response, the PBPD Records Specialist provided the Government with 60 pages of documents, which the Prosecution Team reviewed for any material that is non-duplicative and warrants discl
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
pecialist to provide the Prosecution Team with a copy of the files still in PBPD's possession related to the Florida Investigation. In response, the PBPD Records Specialist provided the Government with 60 pages of documents, which the Prosecution Team reviewed for any material that is non-duplicative and warrants discl
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
pecialist to provide the Prosecution Team with a copy of the files still in PBPD's possession related to the Florida Investigation. In response, the PBPD Records Specialist provided the Government with 60 pages of documents, which the Prosecution Team reviewed for any material that is non-duplicative and warrants discl
, 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
pecialist to provide the Prosecution Team with a copy of the files still in PBPD's possession related to the Florida Investigation. In response, the PBPD Records Specialist provided the Government with 60 pages of documents, which the Prosecution Team reviewed for any material that is non-duplicative and warrants discl
Entities connected to both Alison J. Nathan and PBPD Records Specialist

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Audrey Strauss
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATIONFBI
ORGANIZATION
Martha Stewart
PERSONCollins
PERSON
Brady
PERSON
Giglio
PERSON
Alfredo Rodriguez
PERSON
Southern District of New York
ORGANIZATIONGhailani
PERSONUSAO-SDFL
ORGANIZATIONPalm Beach Resident
LOCATIONPCAOB
ORGANIZATIONthe Prosecution Team Files
ORGANIZATIONGovernment, Public Company Accounting Oversight Board
ORGANIZATION