Epstein Secrets

les as may be applicable." The letter lists 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

U.S. Department of Justice United States Attorney Southern District of New York By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 15

it includes information regarding records designated as "confidential" under the Protective Order. The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and

U.S. Department of Justice United States Attorney Southern District of New York By Email & Hand Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. August 5, 2020 Re: United States v. Ch

s of this letter and its enclosures as "Confidential" under the Protective Order in this case. In recognition of the Government's obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, we write to disclose the following information, in connection with the pending charges against you

f New York The Silvio J. Malta Building One Saint Andrew's Plaza New York, New York 10007 September 14, 2020 BY EMAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 15

it includes information regarding records designated as "confidential" under the Protective Order. The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and

ew York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 August 5, 2020 By Email & Hand Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 15

rk The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 February 26, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 15

viously produced to you in discovery, see SDNY_GM_02742935 and SDNY_GM_02742937. Additionally, in recognition of the Government's obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, we are disclosing the information below. This disclosure should not be taken to indicate that the