EFTA00016136.pdf

Type

pdf

Source set

data-set-8

Original source

Extracted text

Michael C. Miller 
New York. NY 10036 
main 
anewsteptce.com 
By Electronic Mail 
Assistant United States Attorneys 
U.S. Attorney's Office for the 
Southern District of New York 
New York, New York 10007 
Dear 
Steptoe
STEPTOE S .161411SON II 
August 1, 2019 
Re: 
United States v. Jeffrey Epstein. No. 19-cr-00490 
Defendant's Request for Particulars Discovery and Brady Material 
We arc writing on behalf of Jeffrey Epstein regarding discovery in this case. In order to 
preserve Mr. Epstein's rights, arid to request additional information, we respectfully submit this 
formal request for discovery in this case pursuant to the Fourth, Filth and Sixth Amendments to 
the United States Constitution, Rules 12, 16, and 26.2 of the Federal Rules of Criminal 
Procedure, and the additional authority set forth below. 
This request encompasses not only documents and information in your possession, 
custody, or control, but also documents that the government has the legal right or practical ability 
to obtain. Such information includes but is not limited to information in the possession, custody, 
or control of any agency of the United States involved in any way in regulating or investigating 
the activities alleged in the Indictment or related transactions, including but not limited to the 
Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") 
and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), 
and the Department of Homeland Security. In addition, such information includes information in 
EFTA00016136


August 1, 2019 
Page 2 
Steptoe 
Lorna! ailOHNSON LLP 
the possession, custody, and control of any local, state, or foreign law enforcement entities 
involved in any way in regulating or investigating the activities alleged in the Indictment or 
related transactions.' Finally, such information includes information gathered and/or produced 
from private entities aiding in the government's investigat…

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