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0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy
reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy
Page: EFTA00011420 →reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo
Page: EFTA00011422 →22 specific requests (the "Requests"). The letter also makes a general request for materials pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419 (1995), followed by 10 "specific Brady requests." As an initial matter, we take seriously our disclosure obligations, incl
Page: EFTA00030569 →are not aware of any authority requiring us to obtain and/or disclose this information. Request 11 — A Complete, Unredacted Copy of FBI 302 Bearing Bates Numbers SDNY_GM_00114982-00114993: The Government has produced this particular version of the document in the form in which it received the documen
Page: EFTA00030573 →Entities connected to both Bates and Kyles

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSONLaura Menninger
PERSON
Prince Andrew
PERSON
Michael Cohen
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Paul Cassell
PERSONthe Southern District
LOCATION
Christian Everdell
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
George W. Bush
PERSONCohen & Gresser LLP
ORGANIZATIONJack Scarola
PERSONFBI
ORGANIZATIONMark S. Cohen
PERSONBobbi C. Sternheim
PERSON
Brady
PERSON