Epstein Secrets

rida Office investigated and ultimately prosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v. Alfredo Rodriguez,10 Cr. 80015 (KAM), and the Prosecution Team has received some files from that case. The Government does not intend to further seek out or review the inv

States v. Noel and Thomas, 19 Cr. 830 (AT). Separately, the FBI Florida Office investigated and ultimately prosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v. Alfredo Rodriguez,10 Cr. 80015 (KAM), and the Prosecution Team has received some files from that ca

rosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v.

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00092433 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

rida Office investigated and ultimately prosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v. Alfredo Rodriguez,10 Cr. 80015 (KAM), and the Prosecution Team has received some files from that case. The Government does not intend to further seek out or review the inv

States v. Noel and Thomas, 19 Cr. 830 (AT). Separately, the FBI Florida Office investigated and ultimately prosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v. Alfredo Rodriguez,10 Cr. 80015 (KAM), and the Prosecution Team has received some files from that ca

rosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v.

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00097970 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

rida Office investigated and ultimately prosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v. Alfredo Rodriguez,10 Cr. 80015 (KAM), and the Prosecution Team has received some files from that case. The Government does not intend to further seek out or review the inv

States v. Noel and Thomas, 19 Cr. 830 (AT). Separately, the FBI Florida Office investigated and ultimately prosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v. Alfredo Rodriguez,10 Cr. 80015 (KAM), and the Prosecution Team has received some files from that ca

rosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v.

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00098811 Honorable Alison J. Nathan October 7, 2020 Page 8 IV. Conclusion Consistent with its representations to the C

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

rida Office investigated and ultimately prosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v. Alfredo Rodriguez,10 Cr. 80015 (KAM), and the Prosecution Team has received some files from that case. The Government does not intend to further seek out or review the inv

States v. Noel and Thomas, 19 Cr. 830 (AT). Separately, the FBI Florida Office investigated and ultimately prosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v. Alfredo Rodriguez,10 Cr. 80015 (KAM), and the Prosecution Team has received some files from that ca

rosecuted an employee of Epstein's named Alfredo Rodriguez for obstruction of justice, see United States v.

nment will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. EFTA00099677 Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 8 of 8 Honorable Alison J. Nathan October 7, 2020 Page 8

exculpatory material of which it becomes aware. The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior lett

cument 15 Entered on FLSD Docket 01/29/2010 Page 3 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA PENALTY SHEET Defendant's Name: ALFREDO RODRIGUEZ Case No.: I O — (5 -- C War212A/ Nona NJ Count 1: 18 U S 1512(c) Obstruction of Justice 'Max. Penalty: 20 veers Imprisonment: 3 years Supervised R

have previously discussed with some of you, this investigation arises from obstruction of the Operation Leap Year investigation. Alfredo Rodriguez ("Rodriguez") was considered a significant witness in that investigation. Rodriguez had been employed by the target of the Operation Leap Year investigation an

payments, promises of immunity, leniency, preferential treatment, or other inducements made to prospective Government witnesses, within the scope of Giglio vs. United States 405 U.S. 150 (1972), and Napue vs. Illinois 360 U.S. 264 (1959). E. The Government shall supply the defendant(s) with a record o

o be produced "in sufficient time that the defendant will have a reasonable opportunity to act upon the information efficaciously." United States v. Rodriguez, 496 F.3d 221, 226 (2d Cir. 2007). Immediate disclosure of such material is not warranted simply because the defendant prefers it. See, e.g., Unite

der, the Government is prepared to engage in good faith discussions with the defense about an appropriate schedule for disclosure of Jencks Act and Giglio material. The standard practice in this District is to produce such material shortly in advance of trial, a practice that has been widely held to be

Cr. 911 (LBS), 2009 WL 637164, at *14 (S.D.N.Y. March II, 2009) ("The Second Circuit has held that a request for immediate or early disclosure [of Giglio material] has no basis in the law.") Because the Government's brief delay in completing discovery does not entitle the defense to such materials mo

m Beach firm. tier for sexual exploitation of minors. According to a. FBI Cherscies at CaneaceCat Submating Once CMAAAt_ t agent's affidavit, Alfredo Rod- riguez offered to later sell the Information for $50,000 — Rodriguez caning it the "Holy Grail" or 'Golden Nug- get" — to a government wit- ness, who is

e affidavit The affidavit does not refer to Epstein by came, abet In early November. an underawer FBI agent "la: sent it to make the bury from Rodriguez. Rodriggez, born in 1%•', had told police that he worked for Epstein as a butler,' chauffeur, chef and housetanl sometimes pick- ing ul and clean

ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari

L 1494027, at *3 (S.D.N.Y. Apr. 4, 2019) (citing Rodriguez v. Vill. Green Realty, Inc., 788 F.3d 31, 47 (2d

(Id.) On June 2, 2021, the Court adopted the "Government's proposal" and set a deadline of October 11, 2021, for the "disclosure of Jencks Act and Giglio material, Rule 404(b) evidence and 56 EFTA00088858 notice, co-conspirator statements, and Government witness list," as well as the "Defendant's

dy requests." As an initial matter, we take seriously our disclosure obligations, including those arising under Rule 16, Brady and its progeny, and Giglio v. United States, 405 U.S. 150 (1972) and its progeny, and we intend to comply fully with those obligations. We intend to do so irrespective of whe

be produced "in sufficient time that the defendant will have a reasonable opportunity to act upon the information efficaciously." United States v. Rodriguez, 496 F.3d 221, 226 (2d Cir. 2007). Immediate disclosure of such material is not warranted simply because the defendant prefers it. See, e.g., United