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The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. 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 set by the Court.
g and signed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). 06.20.2018 EFTA00040594 Page 3 Bates Start Bates End Confidential
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
g and signed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). Very truly yours, United States Attorney for the Southern District of
The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. 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 set by the Court.
g and signed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). 0620.2018 EFTA00099136 Page 3 Bates Start Bates End Confidential N
Entities connected to both Giglio and Lafler

Jeffrey Epstein
PERSON
Brady
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Michael Cohen
PERSON
Scarlett Johansson
PERSONJane Doe
PERSON
Supreme Court
ORGANIZATIONEmmy Taylor
PERSONSantobello
PERSONLeon Black
PERSONJeffrey Pagliuca
PERSON
Alberto Gonzales
PERSONSouthern District
LOCATION
Kenneth Marra
PERSONMartin Weinberg
PERSON
Bradley Cooper
PERSONLaura Menninger
PERSON