Epstein Secrets

_00007658; SDNY_GM_00007666; SDNY_GM_00007676; SDNY_GM_00007677 T-Mobile records Confidential SDNY GM 00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors) Confidential SDNY_GM_00008137 SDNY_GM_00008137 UMB Bank no records notification Confidential SDNY_

00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors) Con

SDNY GM 00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executo

The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by the Court.

_00007658; SDNY_GM_00007666; SDNY_GM_00007676; SDNY GM_00007677 T-Mobile records Confidential SDNY_GM_00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors) Confidential SDNY_GM_00008137 SDNY_GM_00008137 UMB Bank no records notification Confidential SDNY_

00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors) Con

SDNY_GM_00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executo

The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by the Court.

per week and earned no compensation. (Sag page 6 of each return.) All of these returns were signed under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor." Mr. Epstein's representations concerning his prior work duties and

lary and employment verification requirements of C.O.P. #926.01(V)(CX7) and (8). In response to your requirement of "a detailed work schedule," Mr. Indyke has provided the following two sentences: [Mr. Epstein's] duties will require him to work six days a week, Monday through Saturday, at the Foundat

under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work rele

ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari

per week and earned no compensation. (See page 6 of each return.) All of these returns were signed under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor." Mr. Epstein's representations concerning his prior work duties and

lary and employment verification requirements of C.O.P. #926.01(V)(CX7) and (8). In response to your requirement of "a detailed work schedule," Mr. Indyke has provided the following two sentences: [Mr. Epstein's] duties will require him to work six days a week, Monday through Saturday, at the Foundat

under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work rele

ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari

to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has

arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. The defe

. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni

to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has

harged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d

. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni

to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has

arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d

. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni

to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has

arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d

. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni

to intervene and stay the proceedings in Doe v. Indyke, No. 20 Civ. 484 (JGK), while the Government has

ismissal of an indictment filed within the statute of limitations must establish that the Government acted intentionally, scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The de

not been dismissed on other grounds." (Def. Mot. 7 at 1). As noted above, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial, consistent with whatever schedule the parties agree upon or this Court sets. The Court should re

ached — pending release by Judge Koeltl in Doe v. Indyke, 20 Civ. 484 (JGK) (S.D.N.Y. 2020) 9. Floorplan

ent requests which the defense may want to use in any case-in-chief. Third, the government is still producing Rule 16 discovery, 3500 material, and Giglio material, which may require additional investigation and may, in turn, yield additional documents that the defense may wish to use in any case-in-ch