Epstein Secrets

prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with a

five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00020266 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

ict. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of

prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with a

five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00022096 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

ict. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of

he NPA to plead guilty in Florida state court to soliciting minors for prostitution and to serve eighteen months in a county jail. Id. In exchange, the U.S. Attorney's Office agreed not to charge him with federal crimes in the Southern District of Florida stemming from its investigation of his conduct between 2001 and 20

five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00029545 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen

ict. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of

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

ally found that disclosures made approximately 30 to 45 days prior to trial constitute "reasonable notice" to defendants) (quoting United States v. Nachamie, 91 F. Supp. 2d 565, 577 (S.D.N.Y. 2000); Giffen, 379 F. Supp. 2d at 344 (Rule 404 does not obligate the Government to provide "unduly early notice