Epstein Secrets

ced to Mr. Epstein. F. Finally, Mr. Epstein notes Rule 4.C.3 of Judge Berman's Individual Practices, which, inter alia, (1) requires disclosure of Brady materials within two weeks of its discovery; (2) re-affirms that the government's obligation applies "regardless of whether the Government 'credits

k 10007 Steptoe STEPTOE S .1(11.01CON I I Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for Particulars Discovery and Brady Material Dear Ms. Comey, Ms. Moe, and Mr. Rossmiller: We arc writing on behalf of Jeffrey Epstein regarding discovery in this case. In order to pr

other documents that purport to reflect, relate, or incorporate any statements made by Mr. Epstein. ' Such entities include but are nut limited to the New York Police Department, Manhattan District Attorney's Office, State Attorney's Office for the 15th Judicial District in and for Palm Beach County, the Palm Beach County S

en the Department of Justice and Mr. Epstein (the "NPA"). Each is subject to disclosure pursuant to the government's obligations under, inter alia. Brady v. Maryland, 373 U.S. 83 (1963) and the Federal Rules of Criminal Procedure. Mr. Epstein seeks all documents, communications, and/or tangible objec

he Southern District of New York (or FBI agents working therewith) by the United States Attorney's 2 Such entities include, but arc not limited to, the New York Police Department, Manhattan District Attorney's Office, State Attorney's Office for the 15th Judicial District in and for Palm Beach County, the Palm Beach County S

en the Department of Justice and Mr. Epstein (the "NPA"). Each is subject to disclosure pursuant to the government's obligations under, inter alia, Brady v. Maryland, 373 U.S. 83 (1963) and the Federal Rules of Criminal Procedure. Mr. Epstein seeks all documents, communications, and/or tangible objec

he Southern District of New York (or FBI agents working therewith) by the United States Attorney's 2 Such entities include, but are not limited to, the New York Police Department, Manhattan District Attorney's Office, State Attorney's Office for the 15th Judicial District in and for Palm Beach County, the Palm Beach County S

en the Department of Justice and Mr. Epstein (the "NPA"). Each is subject to disclosure pursuant to the government's obligations under, inter alia. Brady v. Maryland, 373 U.S. 83 (1963) and the Federal Rules of Criminal Procedure. Mr. Epstein seeks all documents, communications, and/or tangible objec

he Southern District of New York (or FBI agents working therewith) by the United States Attorney's 2 Such entities include, but arc not limited to, the New York Police Department, Manhattan District Attorney's Office, State Attorney's Office for the 15th Judicial District in and for Palm Beach County, the Palm Beach County S

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

ited States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the fu

other documents that purport to reflect, relate, or incorporate any statements made by Mr. Epstein. ' Such entities include but are nut limited to the New York Police Department, Manhattan District Attorney's Office, State Attorney's Office for the 15th Judicial District in and for Palm Beach County, the Palm Beach County S

entify the "other" overt acts ("the following overt acts, among others") referenced in ¶ 22 of the indictment. IV. Brady Material A. Pursuant to Brady v. Maryland, 373 U.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)