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Case 1:20-cr-00330-PAE Document 239 _ Filed 04/23/21 Page3of6 Page 3 also noting what the Government has not done and does not believe it is obligated to do with respect to materials that are potentially related to the NPA. B. The Prosecution Team’s Files As the Court is aware, the charges in this case arose from an investigation opened in 2018 and conducted by the United States Attorney’s Office for the Southern District of New York (“SDNY”), the Federal Bureau of Investigation (“FBI”) New York Office, and the New York Police Department (“NYPD”; collectively, the “Prosecution Team”). (Dkt. No. 63 at 1). The Government has obtained the full investigative file from the FBI’s Palm Beach Resident Agency (the “FBI Florida Office”), which conducted a separate investigation and prosecution of Jeffrey Epstein between 2005 and 2010 (the “FBI Florida File”), and whose file also contained the investigative file for the Palm Beach Police Department (“PBPD”) related to that same investigation (the “Florida Investigation”). The Government has reviewed and produced all Rule 16 materials, including potential Brady material, contained within the Prosecution Team’s Files, including the FBI Florida File and the PBPD file. The Government has not identified anything within the files of the Prosecution Team, the FBI Florida File, or the PBPD file that constitutes Brady material with respect to the NPA. C. The Government’s Collection and Review of Other Agencies’ Files On October 7, 2020, the Government submitted a letter to the Court setting forth its plan for collecting and reviewing certain files from other agencies with potential relevance to this case. (Dkt. No. 63). Although Second Circuit law did not require the Government to do so because those other agencies were not part of the Prosecution Team, the Government endeavored to collect and review certain of those materials as part of its commitment to go above and beyond its disclosure obligations. (/d. at 4). In particular, the Government noted its intention to collect: (1) DOJ-OGR-00003957