Epstein Secrets

il shortly before trial); Gov. Ltr. dated Oct. 7, 2020, Dkt. No. 63, at 2 (noting that Rule 16 does not require production of witness statements or Giglio); Gov. Ltr. dated Oct. 20, 2020, Dkt. No. 65, at 1-2 (noting well-established law in this Circuit precluding defense from offering evidence that a

Aug. 25, 2020, Dkt. 49, at 2). Most notably, the defendant's accusations against the Government rely on a blurring of the line between Rule 16 and Giglio or Jencks Act material, as well as the same faulty definition of exculpatory material that has no basis in law. (See Gov. Ltr. dated Aug. 13, 2020,

e clear, the Government has always viewed FBI files from both the prior Florida investigation and the more recent New York investigation as part of the Prosecution Team's files, and stated as much at the makes this assertion despite the fact that neither this Office nor the defendant were party to that agreement, the

tly as possible in advance of trial. Finally, given the expanded charges in the S2 Indictment, the Government is prepared to produce Jencks Act and Giglio material for witnesses it expects to call at trial six weeks, rather than four weeks, in advance of trial. These productions, together with the guid

o 1997). As a result, the Government has already produced to the defense all Rule 16 material relevant to the S2 Indictment of which it is aware in the Prosecution Team's possession. These Rule 16 materials included productions from the files of the Federal Bureau of Investigation ("FBI") Palm Beach Resident Agency (

tly as possible in advance of trial. Finally, given the expanded charges in the S2 Indictment, the Government is prepared to produce Jencks Act and Giglio material for witnesses it expects to call at trial six weeks, rather than four weeks, in advance of trial. These productions, together with the guid

o 1997). As a result, the Government has already produced to the defense all Rule 16 material relevant to the S2 Indictment of which it is aware in the Prosecution Team's possession. These Rule 16 materials included productions from the files of the Federal Bureau of Investigation ("FBI") Palm Beach Resident Agency (