Epstein Secrets

uant to 28 U.S.C. § 1746: 1. I am a partner at Cohen & Gresser LLP, counsel for defendant Ghislaine Ma

instead indicated that it would disclose the identities of Victims 1-3 through its production of Rule 16 discovery, or as part of its production of Jencks Act material closer to trial. EFTA00018578 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 39 Filed 08/10/20 Page 2 of 2 I hereby certify th

y Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq.

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

y Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New

(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

y Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. ohen & Gresser LLP Laura Menninger, Esq.

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