DOJ-OGR-00003148.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 214 of 239
Government has reviewed the full report and confirmed that there is nothing exculpatory contained
therein. To the contrary, the report inculpates the defendant. Accordingly, the defendant is not
entitled to its immediate disclosure. The Government will produce an unredacted version of this
document together with all other witness statements in advance of trial.®”
Fourth, the defense requests production of pages from a personal diary that is in the custody
of a civilian third party and is not in the custody or control of the Government. (Def. Mot. 10 at
10). Leaving aside the fact that the defense cites no authority for the proposition that the
Government has an obligation to obtain the personal papers of a third party, see United States v.
Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (“The Government’s ‘Brady obligations extend
only to materials within prosecutors’ possession, custody or control or, in appropriate cases, that
of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state
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authority involved in the federal prosecution.’” (quoting United States v. Blaszczak, 308 F. Supp.
3d 736, 742 (S.D.N.Y. 2018))), the Government has already represented that it has asked the third
party at issue about the materials the defendant purports to seek and that no such materials exist.
In particular, to the extent the defense is concerned with whether there are diary entries from the
spring of 1996, the Government has already indicated in response to the defendant’s second bail
motion that it is aware of none. (See Dkt. No. 100 at 11 n. 2 (“Because this victim stopped writing
in her journal about a month after that first meeting with Epstein, there are no entries regarding the
subsequent trip she took months later to visit Epstein, during which she met the defendant. This
victim provided the Government with copies of her journal entries relating to Epstein and informed
the Government that the remaining entries are personal in nature and have nothing to do with
6” As is the case with the other redacted document referenced in this motion, the redacted copy
defense counsel attached as Exhibit D was recovered during the execution of a search warrant for
one of Epstein’s devices and was produced to defense counsel in the form in which it was
recovered from the device.
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DOJ-OGR-00003148
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00003148.jpg |
| File Size | 798.0 KB |
| OCR Confidence | 94.2% |
| Has Readable Text | Yes |
| Text Length | 2,440 characters |
| Indexed | 2026-02-03 16:31:28.289433 |