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

of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg

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

of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg

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

of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg

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

of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg

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

of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg

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.

Government and SEC); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (Chin, J.) (no joint investigation between Government and New York Stock Exchange ("NYSE")); United States v. Upton, 856 F. Supp. 727, 749-50 (E.D.N.Y. 1994) (holding that USAO and Federal Aviation Administration ("FAA") did not