Epstein Secrets

recognizes and has complied with its disclosure obligations under Brady,' defendants' request for immediate or otherwise early production of Brady materials is denied." (internal citation omitted) (quoting United States v. Perez, 940 F. Supp. 540, 553 (S.D.N.Y.1996))); Gallo,I999 WL 9848, at *8

e counsel of this single line 66 Notably. the unredacted report does not contain demonstrating that defense counsel's speculation about supposed Brady material lurking beneath redactions is inaccurate. The redacted copy defense counsel attached as Exhibit C was recovered during the execution of a s

d with a jury drawn from the "Long Island Division." Yet the Second Circuit rejected the defendant's claimed entitlement to a jury drawn from Kings, Queens and Richmond counties, or the entire Eastern District, because that argument—like the defendant's here—was based on a flawed premise. The defendan

mptly produce any potentially exculpatory material if any is identified during that review. The Government is not currently aware of any undisclosed Brady material in its possession, but it will certainly provide timely disclosure of any additional Brady material if any such material comes to light. C

itness "M." of this single line " Notably, the unredacted report does not contain demonstrating that defense counsel's speculation about supposed Brady material lurking beneath redactions is inaccurate. The redacted copy defense counsel attached as Exhibit C was recovered during the execution of a s

d with a jury drawn from the "Long Island Division." Yet the Second Circuit rejected the defendant's claimed entitlement to a jury drawn from Kings, Queens and Richmond counties, or the entire Eastern District, because that argument—like the defendant's here—was based on a flawed premise. The defendan

mptly produce any potentially exculpatory material if any is identified during that review. The Government is not currently aware of any undisclosed Brady material in its possession, but it will certainly provide timely disclosure of any additional Brady material if any such material comes to light. C

itness "M." of this single line " Notably, the unredacted report does not contain demonstrating that defense counsel's speculation about supposed Brady material lurking beneath redactions is inaccurate. The redacted copy defense counsel attached as Exhibit C was recovered during the execution of a s

d with a jury drawn from the "Long Island Division." Yet the Second Circuit rejected the defendant's claimed entitlement to a jury drawn from Kings, Queens and Richmond counties, or the entire Eastern District, because that argument—like the defendant's here—was based on a flawed premise. The defendan

bligation to obtain the personal papers of a third party, see United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) ("The Government's `Brady obligations extend only to materials within prosecutors' possession, custody or control or, in appropriate cases, that of the Department of Justice

tentially exculpatory material if any is identified during that review. 188 EFTA00095280 The Government is not currently aware of any undisclosed Brady material in its possession, but it will certainly provide timely disclosure of any additional Brady material if any such material comes to light. C

d with a jury drawn from the "Long Island Division." Yet the Second Circuit rejected the defendant's claimed entitlement to a jury drawn from Kings, Queens and Richmond counties, or the entire Eastern District, because that argument—like the defendant's here—was based on a flawed premise. The defendan

mptly produce any potentially exculpatory material if any is identified during that review. The Government is not currently aware of any undisclosed Brady material in its possession, but it will certainly provide timely disclosure of any additional Brady material if any such material comes to light. C

fense counsel of this single line Notably, the unredacted report does not contain demonstrating that defense counsel's speculation about supposed Brady material lurking beneath redactions is inaccurate. The redacted copy defense counsel attached as Exhibit C was recovered during the execution of a s

d with a jury drawn from the "Long Island Division." Yet the Second Circuit rejected the defendant's claimed entitlement to a jury drawn from Kings, Queens and Richmond counties, or the entire Eastern District, because that argument—like the defendant's here—was based on a flawed premise. The defendan

torney's Office. Also consistent with the October 7, 2020 letter, we have taken the following steps to obtain additional agency files to review for Brady, Giglio, and Jencks Act material. First, we have confirmed with the U.S. Attorney's Office in Georgia that it does not possess any substantive witn

re the minor victim testified that she was in SDNY when the defendant first contacted her over Facebook and encouraged her to travel to meet him in Queens. See United States v. Walsh, 827 F. App'x 30, 33 (2d Cir. 2020). The remaining conduct, including in-person grooming and all commercial sex acts, th

nnsylvania, which spent $2 million to repair damage by the malware, U.S. Attorney Scott Brady said at a Monday news conference in Washington, D.C." Brady "and other officials said the Russian officers are part of the same unit that the Justice Department said attempted to disrupt the 2016 election and

ghly two weeks after the color-coded shutdowns of schools and non-essential businesses were first implemented in parts of southern Brooklyn, central Queens, Rockland County, Orange County and some areas of upstate." Cuomo "did not divulge the exact nature of the tweaks, but said they could be made on a

nnsylvania, which spent $2 million to repair damage by the malware, U.S. Attorney Scott Brady said at a Monday news conference in Washington, D.C." Brady "and other officials said the Russian officers are part of the same unit that the Justice Department said attempted to disrupt the 2016 election and

ghly two weeks after the color-coded shutdowns of schools and non- essential businesses were first implemented in parts of southern Brooklyn, central Queens, Rockland County, Orange County and some areas of upstate." Cuomo "did not divulge the exact nature of the tweaks, but said they could be made on a

nnsylvania, which spent $2 million to repair damage by the malware, U.S. Attorney Scott Brady said at a Monday news conference in Washington, D.C." Brady "and other officials said the Russian officers are part of the same unit that the Justice Department said attempted to disrupt the 2016 election and

ghly two weeks after the color-coded shutdowns of schools and non- essential businesses were first implemented in parts of southern Brooklyn, central Queens, Rockland County, Orange County and some areas of upstate." Cuomo "did not divulge the exact nature of the tweaks, but said they could be made on a