EFTA00016136.pdf

"We arc writing on behalf of Jeffrey Epstein regarding discovery in this case."

"Michael C. Miller Steptoe"

"Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for Particulars Discovery and Brady Material"

"Assistant United States Attorneys U.S. Attorney's Office for the Southern District of New York Re: United States v. Jeffrey Epstein. No. 19-cr-00490"

"Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI")"

"New Mexico Attorney General's Office, which recently confirmed that it would he sharing evidence with "New York prosecutors.""

"Balderas Believes Previous Investigations Failed Epstein's AllegedNM Victims"

"Mr. Epstein requests that the government provide the following information relating to the allegations in the Indictment"

"non-prosecution agreement between the Department of Justicc and Mr. Epstein in the matter captioned In re Investigation ofJefikey Epstein, dated Septe"

"plea agreement between the State Attorney's Office for the 15'h Judicial District in and for Palm Beach County and Mr. Epstein, dated that resulted in"

"individuals referenced in the Indictment, including but not limited to Employee-1... and other employees"

"Employee-2"

"Employee-3"

"the 53-page indictment prepared by the FBI in 2006-2007"

"Mr. Epstein did not instigate, control, authorize, approve, or acquiesce in any conduct that is the subject of the Indictment"

"interviews conducted by the U.S. Attorney's Office for the Southern District of New York"

"The identity of Victims 1,2, and/or 3 were known to the Government before June 30, 2008"

"The identity of Victims 1,2, and/or 3 were known to the Government before June 30, 2008"

"The identity of Victims 1,2, and/or 3 were known to the Government before June 30, 2008"

"Steptoe ... Mr. Epstein contends that the foregoing categories of information constitute Brady and Rule 3.8(d) material, and that disclosure should ta"

"the government's obligations extend to law enforcement and regulatory agencies that are or have been involved in the prosecution of the defendant"

"Mr. Epstein requests that the government provide a list of the names and addresses of all witnesses... that the government intends to call in its case"

"investigation of the charges contained in the Indictment"

"legal instructions provided to the grand jury before the Indictment was returned"

"Michael C. Miller [L0084] ... We are available to discuss any of the foregoing requests with you when convenient."

"Martin G Weinberg [L0085] ... We are available to discuss any of the foregoing requests with you when convenient."

"Mr. Epstein during the investigation of the allegations of the Indictment or any related allegations"

"The identities of any informant or undercover agent employed by the government during its investigation of the charges of the Indictment."

"any statement made by Mr. Epstein or any family member"

"August 1, 2019 Steptoe ... Mr. Epstein took steps to prevent minors from entering his residences"

"any computer hard drive or handheld mobile device that Mr. Epstein possessed or to which Mr. Epstein had access"

"Curt Devine, Private Investigator Has Spent A Decade on Jeffrey Epctein's Trail, CNN.com (July 20, 2019)"

"Search Warrants for the E71st residence that were provided in the first discovery production"

"Some or all of the conduct in the Indictment is subject to the NPA"

"Steptoe ... JOHNSON LI"

"Mr. Epstein notes Rule 4.C.3 of Judge Berman's Individual Practices"

"all statements of those witnesses in the possession... of the government... including but not limited to notes of interviews, FBI 302s"

"August 1, 2019 Steptoe ... Michael C. Miller"

"August 1, 2019 Steptoe ... Martin G Weinberg"

"return any non-seized documents (and the media from which they were collected) as soon as possible to Mr. Epstein."

"the government has seized materials — including computers and other portable electronics — that are likely to contain documents and information"

"The alleged victims received money (or other things of value) from Mr. Epstein, whether as gifts or in exchange for things other than sex acts"

"The alleged recruiters or any alleged co-conspirators or accomplices were over the age of eighteen"

"Nicholas Fandos... N.Y. Times (July 11, 2019)"

"States V. Triumph Capital Group, Inc., 544 F.3d 149... finding a Brady violation"