Epstein Secrets

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

broad and blind fishing expedition among items possessed by the Government on the chance that something impeaching might turn up." United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *1 (S.D.N.Y. May 12, 2015) (internal quotation marks omitted). If there are any specific anticipated def

132 (2d Cir. 2001) United States v. Defritas, No. 07 Cr. 543 (DLI), 2011 WL 317964, at *10 (E.D.N.Y. 7, 8 Jan. 31, 2011) 12, 17 United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 (S.D.N.Y. May 12, 2015) 16 United States v. Edwards, 101 F.3d 17 (2d Cir. 1996) 13 United States v

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

32 (2d Cir. 2001) United States v. Defreitas, No. 07 Cr. 543 (DLI), 2011 WL 317964, at *10 (E.D.N.Y. 7, 8 Jan. 31, 2011) 12, 17 United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 (S.D.N.Y. May 12, 2015) 16 United States v. Edwards, 101 F.3d 17 (2d Cir. 1996) 13 United States v

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