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

cluding 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 Practices, Mr. Epstein requests immediate identification and disclosure of all mater

nt with the government's theory of the case." United States v. Harris, No. 00 Cr. 105 (RPP), 2000 WL 1273720, at *2 (S.D.N.Y. Sept. 7, 2000) (citing Kyles v. Whitley, 514 U.S. 419 (1995). 2. Rule 16 Rule 16 provides, in pertinent part: Upon a defendant's request, the government must permit the defe

n re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) 15 Kyles v. Whitley, 514 U.S. 419 (1995) 19 N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975) 26 Nat'l Res. Del Council v. United States Ening. Prot.

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

n re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) 15 Kyles v. Whitley, 514 U.S. 419 (1995) 19 N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975) 26 Nat'l Res. Def. Council v. United States Envtl. Prot.