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

Aff."), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S

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

Aft"), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S

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

Aft"), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S

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

rtin Aft"), which was prepared for the defense in United States v. Balde, 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S

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

Aff."), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S