Epstein Secrets

ons between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative ag

tember 24, 2007. Such communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prose

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

22 specific requests (the "Requests"). The letter also makes a general request for materials pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419 (1995), followed by 10 "specific Brady requests." As an initial matter, we take seriously our disclosure obligations, incl

r disclosure obligation. Nor is the Government aware of any basis in law for this request. We note, in this respect, that neither the defendant nor the U.S. Attorney's Office for the Southern District of New York is a party or signatory to the NPA, nor is the defendant or this Office named therein. As noted in the Govern

do not constitute Giglio or Jencks Act material. Request 14 — All Written and Oral Communications and Other Documents Concerning Meetings between the United States Attorney's Office for the Southern District of New York and Specified Attorneys for the Minor Victims and Other Witnesses: Your request does not articulate a basis i

for honesty, integrity, or competence. 12. Relating to any investigations, interviews, reports, analyses, or other documents provided by, or to, the U.S. Attorney's Office for the Southern District of New York, the Department of Justice, the FBI, or any state or local government or regulatory body or agency, in connec

cluding 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. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests immediate identification and disclosure of all mater

n re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) 15 Kyles v. Whitley, 514 U.S. 419 (1995) 19 N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975) 26 Nat'l Res. Del Council v. United States Ening. Prot.

Discussion As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the Unite

n re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) 15 Kyles v. Whitley, 514 U.S. 419 (1995) 19 N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975) 26 Nat'l Res. Def. Council v. United States Envtl. Prot.

Discussion As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the Unite