Epstein Secrets

Y investigation into this case (see Dkt. 63), or at any time thereafter. 15. We request the complete FBI's case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the government's production cover letter of August 21, 2020. 16. We request copies of the "82-page pros m

case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the gov

and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search for, locate, i

case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the gov

Y investigation into this case (see Dkt. 63), or at any time thereafter. 15. We request the complete FBI's case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the government's production cover letter of August 21, 2020. 16. We request copies of the "82-page pros m

and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search for, locate, i

STATE INC. FINANCIAL TRUST COMPANY, INC. PLAN D, INC. FLIGHT LOGS 2007 WEXNER TRUSTS BINDER Depositions Document Productions Reed From Critton Alfredo Rodriguez, July 29, 2009 EFTA00298042 Correspondence of ALL Cases Witness Files: Witness File Witness File BINDER: Leslie H. Wexner Sale of Nine East 71

Document Productions Reed From Critton Alfredo Rodriguez, July 29, 2009 EFTA00298042 Correspondence of

RCH FOURTH DRAWER: PALM BEACH LITIGATION -Non-Prosecution Agreement and Addendum -June 12, 2008 Draft DOJ Letter -Letter to Filip from Starr and Whitley (5-27-08) -March 28, 2008 Letter to DOJ -DOJ Submission (Summary) -DOJ Submission (Attachment Letter) -April 8, 2009 Submission to Hon. Mandelker

write a statute as it pleases." It • Jennings v. Rodriguez, 538 U.S. -, 138 S. Ct. 830, 843-44, 200 L.Ed.2

39, 117 S. Ct. 417, 421, 136 L.Ed.2d 347 (1996) ("We have long held that the 'touchstone of the Fourth Amendment is reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S. 83, 83 S. Ct

fic requests (the "Requests"). The letter also makes a general request for materials pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419 (1995), followed by 10 "specific Brady requests." As an initial matter, we take seriously our disclosure obligations, including those

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