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

015,2016, 2017,and 2018 survey data. (Id.). 208 EFTA00100175 source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

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

5, 2016, 2017, and 2018 survey data. (Id.). 208 EFTA00077840 source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

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

5, 2016, 2017, and 2018 survey data. (Id.). 208 EFTA00039655 source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

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

P]erfectly proportional representation is not required, since no source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

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

5, 2016, 2017, and 2018 survey data. (Id.). 208 EFTA00103233 source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

igate crimes with which the defendant is not charged. Moreover, the defense's most recent letter refers to these materials as somehow constituting Brady material without any explanation of what information within the most recent production is supposedly exculpatory. But given that, as noted above, a

Because the S2 Indictment was returned more than three months in advance of the July 12, 2021 trial date, the defense's reliance on United States v. Guzman, 754 F.2d 482, 486 (2d Cir. 1985) to support its request for an adjournment is entirely misplaced. In Guzman, the district court ordered the defend