Epstein Secrets

thers") referenced in ¶ 22 of the indictment. IV. Brady Material A. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitne

72), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests immediate identification and disclosure of all materials that are exculpatory, would tend to negate th

y material regarding your client, but will provide timely disclosure if any such material comes to light. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, to the extent it has not already been produced, in a timely manner prior to trial. II

or a "plea offer," as those terms are used in Lafier v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). Very truly yours, GEOFFREY S. BERMAN United States Attorney for the Southern District of New York By: Is/ Assistant United States Attorneys 06.20.2018 EFTA00025245

nd 20." Witness-1 is represented by Rita Glavin, Esq. 06.20.2018 EFTA00018620 --- PAGE BREAK --- Page 4 Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule agreed upon by the

r a "plea offer," as those terms are used in Lafier v. Cooper, 132 S. Ct. 1376 (2012); Missouri v. Fiye, 132 S. Ct. 1399 (2012). Very truly yours, GEOFFREY S. BERMAN United States Attorney by: Enclosure Assistant United States Attorneys 06.20.2018 EFTA00018622

particular, as noted above, to the extent this Office has had communications with any alleged victims or their counsel that constitute 3500 and/or Giglio material, such material will be produced substantially closer to trial and consistent with any schedule agreed upon by the parties or set by the Cou

517 U.S. at 463 ("[U]nder Rule I 6(a)(2), [a defendant] may not examine Government work product in connection with his case."). Very truly yours, GEOFFREY S. BERMAN By Assistant United States Attorneys Southern District of New York Tel: EFTA00027238

MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Assistant United States Attorneys - Of Counsel - EFTA00027307 --- PAGE BREAK --- Case 1:

ep't of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dept of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. 1 (2001) 26, 27 Giglio v. United States, 405 U.S. 150 (1972) In re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E.

y material regarding your client, but will provide timely disclosure if any such material comes to light. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, to the extent it has not already been produced, in a timely manner prior to trial. II

or a "plea offer," as those terms are used in Lafier v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). Very truly yours, GEOFFREY S. BERMAN United States Attorney for the Southern District of New York By: /s/ Assistant United States Attorneys 06.20.2018 EFTA00027738

between the ages of 18 and 20." Please note that Witness-1 is also represented by counsel, Rita Glavin, The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule agreed upon by the

r a "plea offer," as those terms are used in Lafier v. Cooper, 132 S. Ct. 1376 (2012); Missouri v. Fiye, 132 S. Ct. 1399 (2012). Very truly yours, GEOFFREY S. BERMAN United States Attorney by: Enclosure Assistant United States Attorneys 06.20.2018 EFTA00030536

MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Assistant United States Attorneys - Of Counsel - EFTA00031263 --- PAGE BREAK --- TABLE O

t of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dep't of Interior v. Klamath Water Users Protective Ass 'it, 532 U.S. 1 (2001) 26, 27 Giglio v. United States, 405 U.S. 150 (1972) In re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E.

ncerning the same. In your letter, you cite Federal Rule of Evidence 16(a)(1)(E)(i), the Due Process Clause, Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), and their progeny. However, insofar as your request is premised on the proposition that, as you stated in th

we may confer further and then the matter may be raised with the Court. If you do not agree with this request, please advise us. Very truly yours, GEOFFREY S. BERMAN United States Attorney By: Assistant United States Attorneys 06.20.2018 EFTA00032754