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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
s set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin 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 Faill
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
s set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin 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 Faill
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
Rioux, 97 F.3d at 657 ("We conclude that the 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin 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. T
Entities connected to both Brady and Martin Aft"

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Giglio
PERSON
Scarlett Johansson
PERSONLeon Black
PERSONCollins
PERSON
Southern District of New York
ORGANIZATIONEmmy Taylor
PERSONSecond Circuit
ORGANIZATIONCoppa
PERSONBortnovsky
PERSON
Audrey Strauss
PERSONWalker
PERSONAnnabi
PERSON
Cynthia Nixon
PERSONThompson
PERSONRusso
PERSONTracy
PERSONthe White Plains Division
ORGANIZATION