Epstein Secrets

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

22 specific 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, incl

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 9

reporters, 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 fo

ANnW COHEN & GRESSER LLP October 13, 2020 BY EMAIL United

reporters, 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 fo

COHEN & GRESSER LLP .,:m.cohengesser <cm October 13,

reporters, 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 fo

iolation of statutory provisions. It Hardison v. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004); Nichols v

U.S. 33, 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.

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 9

reporters, 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 fo

COHEN & GRESSER LLP Thrd Avenue I ow York. NY 10022

reporters, 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 fo

mid Avenue COHEN & GRESSER LLP October 13, 2020 BY EMAIL , Esq.

reporters, 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 fo

nt 64 Filed 10/14/20 Page 1 of 6 SOO Third 4wnw COHEN & GRESSER LLP October 14, 2020 BY ECF The Hono

nt with the government's theory of the case." United States v. Harris, No. 00 Cr. 105 (RPP), 2000 WL 1273720, at *2 (S.D.N.Y. Sept. 7, 2000) (citing Kyles v. Whitley, 514 U.S. 419 (1995). 2. Rule 16 Rule 16 provides, in pertinent part: Upon a defendant's request, the government must permit the defe

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Maryland, 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 fo

21st Floor New York New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq.