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he Government redefines who it believes is on the Team. The Government claims no responsibility for investigations into these allegations by either the Federal Bureau of Investigation or the Office of the United States Attorney unless part of the Southern District of New York. This stands in stark contrast to the on-the-record as
government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at
impeded an official proceeding, in violation of Title 18 , United Stales Code, Section 1512(c) . I further state that I am a Special Agent with the Federal Bureau of Investigation and that this Complaint is based on the following facts: Please see attached Affidavit Continued on the attached and made a part hereof. Chris ma
t is material to the guilt of Alfredo Rodriguez, regardless of whether that information was requested by the Defendant or not See United States v. Bagley, 473 U.S. 667 (1985). See e Fed.R.Crim P. 16(a)(IXE). Evidence is material that creates a reasonable probability that the outcome of a criminal pr
he Government redefines who it believes is on the Team. The Government claims no responsibility for investigations into these allegations by either the Federal Bureau of Investigation or the Office of the United States Attorney unless part of the Southern District of New York. This stands in stark contrast to the on-the-record as
government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at
he Government redefines who it believes is on the Team. The Government claims no responsibility for investigations into these allegations by either the Federal Bureau of Investigation or the Office of the United States Attorney unless part of the Southern District of New York. This stands in stark contrast to the on-the-record as
government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at
he Government redefines who it believes is on the Team. The Government claims no responsibility for investigations into these allegations by either the Federal Bureau of Investigation or the Office of the United States Attorney unless part of the Southern District of New York. This stands in stark contrast to the on-the-record as
government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at
e activities alleged in the Indictment or related transactions, including but not limited to the Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), and the Department of Homeland Security. In addi
.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests immediate identifica
he Government redefines who it believes is on the Team. The Government claims no responsibility for investigations into these allegations by either the Federal Bureau of Investigation or the Office of the United States Attorney unless part of the Southern District of New York. This stands in stark contrast to the on-the-record as
government witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an at
e activities alleged in the Indictment or related transactions, including but not limited to the Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), and the Department of Homeland Security. In addi
Page: EFTA00016136 →.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests immediate identifica
Page: EFTA00016142 →9, 30, 31 United States v. Armstrong, 517 U.S. 456, (1996) passim United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 19, 25 United States v. Bagley, 473 U.S. 667 (1985) 7 United States v. Barcelo, 628 F. App'x 36 (2d Cir. 2015) 19 United States v. Bass, 536 U.S. 862 (2002) 30, 33 United Sta
Page: EFTA00027309 →e round reports; MCC phone records; personnel records and prior work schedules; and reports and notes of witness interviews prepared by agents from the Federal Bureau of Investigation ("FBI") and the DOJ-OIG who were participating in the investigation.2 Subsequently, the Government made three additional discovery productions, much
Page: EFTA00027314 →9, 30, 31 United States v. Armstrong, 517 U.S. 456, (1996) passim United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 19, 25 United States v. Bagley, 473 U.S. 667 (1985) 7 United States v. Barcelo, 628 F. App'x 36 (2d Cir. 2015) 19 United States v. Bass, 536 U.S. 862 (2002) 30, 33 United Sta
Page: EFTA00031265 →e round reports; MCC phone records; personnel records and prior work schedules; and reports and notes of witness interviews prepared by agents from the Federal Bureau of Investigation ("FBI") and the DOJ-OIG who were participating in the investigation? Subsequently, the Government made three additional discovery productions, much
Page: EFTA00031270 →Entities connected to both FBI and Bagley

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONLeon Black
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
New York
LOCATION
Scarlett Johansson
PERSON
Virginia Giuffre
PERSON
Southern District of New York
ORGANIZATION
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSON