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

a trial held at the Uniondale courthouse. 68 F.3d at 20. Under the relevant jury plan, jurors for trials held in Brooklyn were drawn from the entire Eastern District, while jurors for trials held in the "Long Island Division," which included the Uniondale 200 EFTA00100167 courthouse, were drawn from Nassau an

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

a trial held at the Uniondale courthouse. 68 F.3d at 20. Under the relevant jury plan, jurors for trials held in Brooklyn were drawn from the entire Eastern District, while jurors for trials held in the "Long Island Division," which included the Uniondale 200 EFTA00077832 courthouse, were drawn from Nassau an

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

a trial held at the Uniondale courthouse. 68 F.3d at 20. Under the relevant jury plan, jurors for trials held in Brooklyn were drawn from the entire Eastern District, while jurors for trials held in the "Long Island Division," which included the Uniondale 200 EFTA00039647 courthouse, were drawn from Nassau an

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

a trial held at the Uniondale courthouse. 68 F.3d at 20. Under the relevant jury plan, jurors for trials held in Brooklyn were drawn from the entire Eastern District, while jurors for trials held in the "Long Island Division," which included the Uniondale courthouse, were drawn from Nassau and Suffolk Counties.

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

a trial held at the Uniondale courthouse. 68 F.3d at 20. Under the relevant jury plan, jurors for trials held in Brooklyn were drawn from the entire Eastern District, while jurors for trials held in the "Long Island Division," which included the Uniondale 200 EFTA00103225 courthouse, were drawn from Nassau an

d Order a Bill of Particulars as to Counts Five and Six. 22 VII. The Court Should Order the Government to Produce Accuser-4's Prior Statements as Brady Material 24 VIII. Ms. Maxwell Incorporates All of the Arguments Raised in Her Initial Pretrial Motions and Reasserts Them as to the S2 Indictment

ere arrested at Kennedy Airport on November 23, 1982, in possession of four kilograms of heroin and were charged in a three-count indictment in the Eastern District of New York with (I) conspiracy to import heroin into the United States, (2) a substantive offense of importing heroin, and (3) possession of heroin

Jeopardy Clause's Protection Against Duplicative Punishments. 11 III. The Government Should Immediately Produce Accuser-4's Prior Statements as Brady Material. 14 IV. The Court Should Grant Ms. Maxwell's Other Requested Relief. 16 CONCLUSION 17 i EFTA00104412 TABLE OF AUTHORITIES Page

s opinion that the defendants did not have a Double Jeopardy claim because they "were never in jeopardy with respect to the dismissed counts of the Eastern District indictment." Annabi, 771 F.2d at 671. The court was clear that the defendants' only claim on appeal was that the Southern District indictment "viol