Epstein Secrets

t and BSF. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material ha

in to discovery requests in civil litigation. 3 EFTA00103817 Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 4 of 9 See United States v. Avenatti, No. (SI) I9-CR-373 (PGG), 2020 WL 86768, at *6 (S.D.N.Y. Jan. 6, 2020). But Rule 17(c) subpoenas are not tools of discovery. Nixon, 418 U.S. at 698

ally impeaching statements `ripen into evidentiary material. . . only if and when the witness testifies at trial...." (citation omitted)). See also Avenatti, 2020 WL 86768, at *6 (rejecting the argument that the defendant needed the recordings in question prior to trial in order "to demonstrate witnesses

t and BSF. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material ha

in to discovery requests in civil litigation. 3 EFTA00104688 Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 4 of 9 See United States v. Avenatti, No. (SI) I9-CR-373 (PGG), 2020 WL 86768, at *6 (S.D.N.Y. Jan. 6, 2020). But Rule 17(c) subpoenas are not tools of discovery. Nixon, 418 U.S. at 698

ally impeaching statements `ripen into evidentiary material. . . only if and when the witness testifies at trial...." (citation omitted)). See also Avenatti, 2020 WL 86768, at *6 (rejecting the argument that the defendant needed the recordings in question prior to trial in order "to demonstrate witnesses

t and BSF. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material ha

in to discovery requests in civil litigation. 3 EFTA00081407 Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 4 of 9 See United States v. Avenatti, No. (SI) I9-CR-373 (PGG), 2020 WL 86768, at *6 (S.D.N.Y. Jan. 6, 2020). But Rule 17(c) subpoenas are not tools of discovery. Nixon, 418 U.S. at 698

ally impeaching statements `ripen into evidentiary material. . . only if and when the witness testifies at trial...." (citation omitted)). See also Avenatti, 2020 WL 86768, at *6 (rejecting the argument that the defendant needed the recordings in question prior to trial in order "to demonstrate witnesses

ision series of the New York Times, concerning the same. In your letter, you cite Federal Rule of Evidence 16(a)(1)(E)(i), the Due Process Clause, Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), and their progeny. However, insofar as your request is premised on th

r 5, 2019 BY EMAIL Scott A. Srebnick, Esq. 201 South Biscayne Boulevard, Suite 1210 Miami, FL 33131 [email protected] Re: United States v. Michael Avenatti, Si 19 Cr. 373 (PGG) Dear Mr. Srebnick: We write in response to your letter dated December 2, 2019, which requests certain information in light o

se was examining his diary, . . . he requested that this not be done." Id. While the parties were discussing how to review the diary, including for Brady material, the diary was returned to the witness. It was only given to the defense for examination after "roughly five days" in the witness's possess

that something useful will turn up." Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g., United States v. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 508682, at *4 (S.D.N.Y. Jan. 31, 2020). The defendant's request for the entire diary is likely to sweep in a signific

ests in civil litigation. 3 EFTA00020300 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 4 of 9 See United States v. Avenatti, No. (SI) I9-CR-373 (PGG), 2020 WL 86768, at *6 (S.D.N.Y. Jan. 6, 2020). But Rule 17(c) subpoenas are not tools of discovery. Nixon, 418 U.S. at 698

ally impeaching statements `ripen into evidentiary material. . . only if and when the witness testifies at trial...." (citation omitted)). See also Avenatti, 2020 WL 86768, at *6 (rejecting the argument that the defendant needed the recordings in question prior to trial in order "to demonstrate witnesses

t and BSF. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material ha

se was examining his diary, . . . he requested that this not be done." Id. While the parties were discussing how to review the diary, including for Brady material, the diary was returned to the witness. It was only given to the defense for examination after "roughly five days" in the witness's possess

that something useful will turn up." Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g., United States v. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 508682, at *4 (S.D.N.Y. Jan. 31, 2020). The defendant's request for the entire diary is likely to sweep in a signific