evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agurs, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We request all such evidence requested above and e

ial A. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practic

cution team (which is not on any Jeffrey Epstein-related investigation) both had it and was at liberty to provide it. See generally United States v. Agurs, 427 U.S. 97, 109 n.16 (1976). We also note that Scott Wilson, Esq. has moved from BSF to DLA Piper. Notwithstanding this view, we are available to