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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
of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg
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
of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg
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
of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg
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
of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg
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
of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no sugg
USION 29 EFTA00031264 --- PAGE BREAK --- TABLE OF AUTHORITIES Cases 27 passim Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010) Brady v. Maryland, 373 U.S. 83 (1963) Color of Change v. United States Dep't of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dep't of Interior
Page: EFTA00031265 →uld be disclosed when defendants make a 7 EFTA00031274 --- PAGE BREAK --- demand for it. 267 F.3d at 146. The court held that as a general rule, Brady and its progeny do not require immediate disclosure of all impeachment material upon a defendant's request. Id. It found that the time required for
Page: EFTA00031275 →Government and SEC); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (Chin, J.) (no joint investigation between Government and New York Stock Exchange ("NYSE")); United States v. Upton, 856 F. Supp. 727, 749-50 (E.D.N.Y. 1994) (holding that USAO and Federal Aviation Administration ("FAA") did not
Page: EFTA00031285 →Entities connected to both Brady and New York Stock Exchange

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Giglio
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONFBI
ORGANIZATIONLeon Black
PERSON
Scarlett Johansson
PERSONCollins
PERSON
Southern District of New York
ORGANIZATION
Donald Trump
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Supreme Court
ORGANIZATION
Marc Rich
PERSON