EFTA00032751.pdf

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Source set: data-set-8

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LAW orFucts
SCOTT A. SREBNICK, P.A.
SCOTT A. SREBNICK'
, ALSO ADMITTED IN NEW YORK
December 2, 2019
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Re:
United States v. Michael Avenatti
Case No. Si 19 Cr 373 (PGG)
Gentlemen:
201 S. Biscayne Boulevard
Salle 1210
Miami, Florida 33131
Tel 305-285-9019
Far 305-377-9937
sco0€'srcbnicklawcom
write subakklatecom
On behalf of Mr. Avenatti, we make the request below pursuant to Rule 16(a)(1)(EXi) and
the government's obligations under the Due Process Clause, Brady v. Maryland, 373 U.S. 83
(1963), Giglio v. United States, 405 U.S. 150 (1972), and their progeny. This request is meant to
direct the government's attention to specific evidence. It is not intended to be a substitute for
general categories of evidence that the government is otherwise required to produce under the Due
Process Clause and the above authorities (e.g., plea agreements, deferred prosecution agreements,
non-prosecution agreements, promises and benefits to witnesses, threatened charges against
witnesses, etc.), all of which we request as well.
On Saturday, November 30, 2019, the New York Times ("Times") published an
investigative report entitled "Jeffrey Epstein, Blackmail, and a Lucrative 'Hot List'." See
httns://www.nvtimes.com/2019/11/30/business/david-boies-pottinger-ieffrev -eostein-
videos.html. The Times reported about an agreement between David Boies, the founder of the
Boies Schiller Flexner ("BSF") law firm and its Chairman and Managing Partner since 1997, and
attorney John Stanley Pottinger, to purchase what they believed to be videos secretly made by
Jeffrey Epstein of famous wealthy men engaged in sexual activities with different women at
Epstein's residence. The videos were supposedly in the possession of a man who identified himself
to Boies as Patrick Kessler. Because the videos were purportedly made at Epstein's direction,
Boles and Pottinger undo…

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