3
Shared Docs
3
Same-Page
3 / 3
Mentions
trying to "distance itself from its own files" (Def. Ltr. 5), the Government has thoroughly reviewed those files for Rule 16 material and potential Brady material, has made discovery productions from those files beginning in August through this month, and is continuing to make productions from those f
e clear, the Government has always viewed FBI files from both the prior Florida investigation and the more recent New York investigation as part of the Prosecution Team's files, and stated as much at the makes this assertion despite the fact that neither this Office nor the defendant were party to that agreement, the
ill promptly disclose such evidence to the defense as either Rule 16 or Jencks Act material. Additionally, the Government remains cognizant that its Brady obligations remain ongoing and will promptly disclose any exculpatory evidence of which it becomes aware. EFTA00080582 Page 2 I. Comparison of
o 1997). As a result, the Government has already produced to the defense all Rule 16 material relevant to the S2 Indictment of which it is aware in the Prosecution Team's possession. These Rule 16 materials included productions from the files of the Federal Bureau of Investigation ("FBI") Palm Beach Resident Agency (
ill promptly disclose such evidence to the defense as either Rule 16 or Jencks Act material. Additionally, the Government remains cognizant that its Brady obligations remain ongoing and will promptly disclose any exculpatory evidence of which it becomes aware. EFTA00099166 Page 2 I. Comparison of
o 1997). As a result, the Government has already produced to the defense all Rule 16 material relevant to the S2 Indictment of which it is aware in the Prosecution Team's possession. These Rule 16 materials included productions from the files of the Federal Bureau of Investigation ("FBI") Palm Beach Resident Agency (
Entities connected to both Brady and the Prosecution Team's

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Giglio
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
White Plains
LOCATION
Audrey Strauss
PERSONBates
PERSONPalm Beach Resident
LOCATIONThe Silvio J. Mollo Building
ORGANIZATIONthe "FBI Florida Office
ORGANIZATIONMinor Victim-4's month
ORGANIZATION