EFTA00030569Set 8
2020-10-2810p5,387w
take seriously our disclosure obligations, including those arising
under Rule 16, Brady and its progeny, and Giglio v. United States, 405 U.S. 150 (1972) and its
progeny, and we intend ... hereinafter "3500 material") or Giglio v. United States, 405 U.S. 105 (1972)
and its progeny (hereinafter "Giglio material"). As you are aware, it is the standard practice in this
District ... pecific Brady requests": The Government recognizes its obligations under Brady and
its progeny and will provide timely disclosure if and when such material comes to light. With
respect to your
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EFTA00800982Set 9
134p25,947w
permit
20 those questions to be asked, finding,
21 consistent with Frazier and its progeny,
22 that such information will be able to be
23 proffered or testified to outside ... evidence that I
4 have probably seen myself that would support
Frazier and its progeny's analysis as it
6 relates to not allowing simply the
7 invocation ... Amendment invocation
3 with the factors that we discussed in
4 Frazier and its progeny, I am going to find
5 that these questions would be permissible
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EFTA01277705Set 10
2014-02-02252p123,956w
Through the Bank be related Ice this purpose benne they have owners
setrities. Sweep Progeny, cash balances re swept to U16 Birk • Commodities contacts (e.g, foreign exchange and who also ... Through tie Bank be related Ice this purpose totem they have owners
*vain. Sweep Progeny, cah balances re swept to U16 Berk • Commodities contacts (e.g, linen excha
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EFTA00603737Set 9
17p11,455w
change the net growth rate of the cell (birth
minus death), and enable its progeny to outgrow surrounding cells. As
these small lesions grow, the cells acquire additional alterations that ... assume that the cell that initiated the lesion was sensitive to treatment but its
progeny may become resistant. Before the therapy commences. all cells have the tumour is larger than ... five times
constant rate and push away other cells to make space for their progeny. more often. In this case, driver mutations arise earlier than
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EFTA01277221Set 10
2014-02-02158p93,479w
interest
requiredby law to report to the IRS all taxabk dividend, brach (Bank Sweep Progeny), money market metal pg., limited partnere* and prime placements) the Statement liouseholdne
nipple* rantanble ... required by law to report to tot IRS all taxable dividend, brads (Bank Sweep Progeny), money market mutual pg., limited partnashix and pinto placements) the Statement liouseholdhe
reposed* rchtnabla *kends ... Bank be related la this purpose bet&At they haw owners
secwitin. Sweep Progeny, cash balances re swept to U16Bak • Commodities contacts (e.g, laeign eccha-ge and who also maintain
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01277221.pdf
EFTA00791869Set 9
2019-03-1527p6,343w
than permit that court to exercise its discretion under Nixon and its
Second Circuit progeny. The deviation from Nixon is predicated on the panel's
apparent conclusions that the district ... should
conduct the right-to-access balancing, it misapprehended Nixon and its Second
Circuit progeny.
13
EFTA00791882
Case 18-2868, Document 141, 03/15/2019, 2519388, Page15 of 27
B. An appellate ... such materials in the
summary judgment record.
Conclusion
As Nixon and its Second Circuit progeny recognize, the district court —not
this Court —should determine the proper balance between the public
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EFTA00025239Set 8
2019-12-317p1,792w
Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963),
and its progeny. The Government wishes to bring your attention to the following statements,
which could constitute Brady ... provide material under Giglio v. United States, 405 U.S. 150, 154
(1972), and its progeny, to the extent it has not already been produced, in a timely manner prior
https://www.justice.gov/epstein/files/DataSet%208/EFTA00025239.pdf
EFTA00023329Set 8
2020-10-146p2,086w
government's obligations under Brady v. Maryland, 373 U.S. 83 (1963)
and its progeny.'
Second, the Court should order the government to disclose the Materials under Rule 16
because ... October 14, 2020
Page 2
A. Applicable Law
1. Brady
"Under Brady and its progeny, `the Government has a constitutional duty to disclose
favorable evidence to the accused where such
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EFTA00018618Set 8
2019-07-315p1,467w
Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963),
and its progeny. Pursuant to those obligations, we are disclosing the information below. This
disclosure should ... provide material under Giglio v. United States, 405 U.S. 150, 154 (1972),
and its progeny, in a timely manner prior to trial and consistent with the schedule agreed upon
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EFTA00032753Set 8
2019-12-052p509w
Giglio v. United States, 405 U.S. 150 (1972), and their
progeny. However, insofar as your request is premised on the proposition that, as you stated in
the email enclosing your ... understand it to be a request solely for impeachment material under Giglio and its progeny. As
you are aware, the defendant is not entitled to such material at this time
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EFTA00102999Set 9
2019-03-26239p78,398w
broader restriction.
Annabi, 771 F.2d at 672 (citations omitted). Thus, under Annabi and its progeny, a plea agreement
only binds the U.S. Attorney's Office that executes the agreement, even ... binds other districts, and the motion should be denied.
Under Annabi and its progeny, the defendant has failed to establish that the NPA binds other
districts. For this reason alone
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EFTA00087761Set 9
2020-10-078p3,830w
aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will
promptly produce any exculpatory material of which it becomes aware.
The Government ... statements or
material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the
common practice and law within this Circuit. As indicated in a prior
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EFTA00040593Set 9
2020-08-055p1,248w
Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963),
and its progeny. The Government will provide material under Giglio v. United States ... progeny, in a timely manner prior to trial and consistent with the schedule
set by the Court.
Disclosure by the Defendant
In light of your request for discovery in this
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EFTA00091584Set 9
2019-11-199p2,750w
defense that it recognizes and has complied with its obligations under Brady and its progeny."
United States v. Garcia-Pena, No. 17 Cr. 363, 2018 WL 6985220, at *6 (S.D.N.Y ... extent that these motions seek
evidence pursuant to Brady [], Giglio [], and their progeny, they are [denied] on the basis of the
Government's good-faith representation that it has complied
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EFTA00028880Set 8
2016-01-1123p6,182w
appearance—and the government
offers no reasonable alternative interpretation.
Unlike Annabi and its progeny, the NPA here contains significant evidence of the parties'
intent to apply the co-conspirator immunity ... United States" in a plea agreement, without
snore, is insufficient under Annabi and its progeny to demonstrate an intent to bind other
districts, the NPA's references to both
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028880.pdf