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ousing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled t
3. Thomas seeks three categories of information: (1) "[t]re report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's i
that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-
a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material." United States v. Abdalla, 317 F. Supp. 3d 786, 790 (S.D.N.Y. 2018) (internal quotation marks and citation omitted). "There must be some indication that the pretrial disclosu
ousing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled t
3. Thomas seeks three categories of information: (1) "[t]re report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's i
that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-
a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material." United States v. Abdalla, 317 F. Supp. 3d 786, 790 (S.D.N.Y. 2018) (internal quotation marks and citation omitted). "There must be some indication that the pretrial disclosu
ousing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled t
3. Thomas seeks three categories of information: (1) "[t]re report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's i
that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-
a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material." United States v. Abdalla, 317 F. Supp. 3d 786, 790 (S.D.N.Y. 2018) (internal quotation marks and citation omitted). "There must be some indication that the pretrial disclosu
rtin G. Weinber P.C. Boston, MA 02116 Reid Weingarten, Esq. Michael Miller, Esq. Ste toe & Johnson LLP New York, NY 10036 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Mr. Weinberg: The Government writes in response to your letters dated July 26, 2019, requesting preservation and production
Page: EFTA00016596 →on LLP New York, NY 10036 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Mr. Weinberg: Th
Page: EFTA00016596 →a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material.' United States v. Abdalla, 317 F.Supp.3d 786, 790 (S.D.N.Y. 2018) (quoting United States v. Urena, 989 F.Supp.2d 253, 261 (S.D.N.Y. 2013)). Notably, "if the purported defens
Page: EFTA00016597 →, custody, or control of this Office, irrespective of the source from which those files were obtained. Third Request: Communications regarding Mr. Epstein between and among "Main Justice" (including the Child Exploitation and Obscenity Section) and the United States Attorney's Offices for the Southern
Page: EFTA00016598 →tained. Third Request: Communications regarding Mr. Epstein between and among "Main Justice" (including the
Page: EFTA00016598 →on LLP New York, NY 10036 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Mr. Weinberg: Th
Page: EFTA00027234 →rtin G. Weinber P.C. Boston, MA 02116 Reid Weingarten, Esq. Michael Miller, Esq. Ste toe & Johnson LLP New York, NY 10036 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Mr. Weinberg: The Government writes in response to your letters dated July 26, 2019, requesting preservation and production
Page: EFTA00027234 →a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material.' United States v. Abdalla, 317 F.Supp.3d 786, 790 (S.D.N.Y. 2018) (quoting United States v. Urena, 989 F.Supp.2d 253, 261 (S.D.N.Y. 2013)). Notably, "if the purported defens
Page: EFTA00027235 →n produced as part of the Government's initial discovery production to the defendant on July 31, 2019. Third Request: Communications regarding Mr. Epstein between and among "Main Justice" (including the Child Exploitation and Obscenity Section) and the United States Attorney's Offices for the Southern
Page: EFTA00027236 →, 2019. Third Request: Communications regarding Mr. Epstein between and among "Main Justice" (including the
Page: EFTA00027236 →Entities connected to both Jeffrey Epstein and Abdalla

United States
LOCATION
Harry Reid
PERSONJane Doe
PERSONMartin Weinberg
PERSON
Reid Weingarten
PERSON
Geoffrey S. Berman
PERSON
Metropolitan Correctional Center
ORGANIZATION
Southern District of New York
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Michael Milken
PERSON
Supreme Court
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATIONU.S. Attorney's Office
ORGANIZATIONCollins
PERSON
Brady
PERSON
Department of Homeland Security
ORGANIZATION
Giglio
PERSON
Rivera
PERSONthe Middle District
LOCATION
Armstrong
PERSON