Epstein Secrets

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00087767 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00092433 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00097970 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00098811 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00099677 Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 8 of 8 Honorable Alison J. Nathan October 7, 2020 Page 8

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

ers of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for hi

s Office. Also consistent with the October 7, 2020 letter, we have taken the following steps to obtain additional agency files to review for Brady, Giglio, and Jencks Act material. First, we have confirmed with the U.S. Attorney's Office in Georgia that it does not possess any substantive witness stat

lly relevant to our case. We are in the process of reviewing that subset of emails. Third, we are still in the process of loading scans of the full USAO-SDFL file into Relativity so that our team can conduct a full review of that file. Due to technical issues with the vendor who scanned the files in Flori

rial. The government's assertion that it can withhold production of Accuser-4's prior statements because they are merely impeachment material under Giglio, and do not rise to the level of exculpatory material under Brady, is unsupported and flatly incorrect. (Opp. 20-22). The government admits that Ac

secutorial overreach. It is no mystery what happened here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "pote

dy requests." As an initial matter, we take seriously our disclosure obligations, including those arising under Rule 16, Brady and its progeny, and Giglio v. United States, 405 U.S. 150 (1972) and its progeny, and we intend to comply fully with those obligations. We intend to do so irrespective of whe

estigation and prosecution of Jeffrey Epstein, as set forth in greater detail in that letter, the Government intends to gather certain martials from USAO-SDFL and conduct targeted searches of that material aimed at identifying potential Giglio or 3500 material for victims or witnesses relevant to this pro