Epstein Secrets

of New York The Si)WaJ. Mono Building One Saint Andrew 's Plaza New York New York 10007 May 4, 2021 B

ocument 269 Filed 05/04/21 Page 7 of 9 Page 7 individual "is a prospective witness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct

admission of civil or criminal liability in regards to any of those who seek compensation from the Trust. See draft proposal from Jay Lelkowitz to Andrew l.nurie dated September 15. 2007. In response, Ms. • nded that the Agreement contain language considering the inclusion of guardian ad Mem in the

, their credibility and the foundations. il' any. for claiming personal istiory. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the Ponta of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to th

y for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant Unit

that "the defense will receive notice of any co-conspirator statements that the Government may seek to introduce through witness statements" in its Jencks Act production. (Gov't Opp. at 192, Dkt. No. 204). The Court denied the motion, explaining that the Court lacked the power to order pretrial discl

e for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Steptoe STEPTO

se us promptly whether the government will be producing Brady material immediately even if it is contained in what might otherwise be considered as Jencks material, or whether you take the position that you arc not obligated to produce such material at this time. EFTA00096241 August 1, 2019 Page 11

ALEXANDER ACOSTA UNITED STATES ATTORNEY By: sl Andrew C Lourie ANDREW C. LOURIE Assistant United Stat

Id.) McDaniel decided to plead guilty near the time of the interview of Melody; accordingly a report of Melody's interview was never prepared and a Jencks disclosure of the report of Amber's interview was never produced because there was no trial. (Id. at ¶¶ 15-17.) Following the change of plea, the P

f New York The SilWoJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 May 4, 2021 B

ocument 269 Filed 05/04/21 Page 7 of 9 Page 7 individual "is a prospective witness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct

Counsel: The Silvio J. Mono Building One Saint Andrew's Plaza New York. New York 10007 October 28, 20

(S.D.N.Y. Jan. 6, 2010) (declining to order immediate disclosure of Giglio material, because the Government stated it would provide both Giglio and Jencks Act material "shortly before trial"); United States v. Davis, No. 06 Cr. 911 (LBS), 2009 WL 637164, at *14 (S.D.N.Y. March 11, 2009) ("The Second C

Counsel: The Silvio J. Mono Building One Saint Andrew's Plaza New York. New York 10007 January 10, 20

ernment's letter dated October 28, 2020, with regard to your many requests for information that fall within the scope of the Government's Giglio and Jencks Act obligations, we intend to produce all such material in advance of trial and remain available to confer generally regarding a mutual schedule fo