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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
cluding 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 identification and disclosure of all mater
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 →cluding 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 identification and disclosure of all mater
Page: EFTA00016142 →n re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) 15 Kyles v. Whitley, 514 U.S. 419 (1995) 19 N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975) 26 Nat'l Res. Del Council v. United States Ening. Prot.
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 →n re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) 15 Kyles v. Whitley, 514 U.S. 419 (1995) 19 N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975) 26 Nat'l Res. Def. Council v. United States Envtl. Prot.
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 Kyles

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Southern District of New York
ORGANIZATION
Joe Biden
PERSON
Geoffrey S. Berman
PERSONMartin Weinberg
PERSON
Michael Cohen
PERSON
Alfredo Rodriguez
PERSONFederal Bureau of Prisons
ORGANIZATION
Paul Cassell
PERSON
Supreme Court
ORGANIZATION
Lesley Groff
PERSONCollins
PERSON