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Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 8 of 38

As stated previously, there is no dispute that multiple investigations by numerous federal agencies were opened to investigate the events surrounding the death of Jeffrey Epstein on August 10, 2019. Michael Thomas is charged with certain crimes resulting from this same event. On August 10, 2019, the Washington Examiner, reported under the headline: “Barr announces DOJ inspector general investigation into Epstein death.” (See Exhibit D.) On December 28, 2019, Reuters reported under the headline: “FBI investigating Jeffrey Epstein’s inner circle.”¹ On September 11, 2019, CNN reported under the headline: “The Jeffrey Epstein investigation was more expansive than previously thought, documents show.”² This news clip refers to what appears to be a separate investigation by the U.S. Marshals Service. On the Wikipedia page entitled, “Death of Jeffrey Epstein,” the following appears, among other information: “After initially expressing suspicion, Attorney General William Barr described Epstein’s death as ‘a perfect storm of screw-ups.’ Both the FBI and U.S. Department of Justice’s Inspector General are conducting investigations into the circumstances of his death.³”

D. The Information Sought by This Motion.

In the minute entry on the docket, of November 25, 2019, this Court noted, among other things, “The Government shall produce discovery to the defense by December 31, 2019.” This discovery was not produced. Because the government has failed to meet the disclosure mandates of Rule 16 and Brady-Giglio, this motion seeks to compel the government to produce the following: 1) Inspector General’s report investigating the death of Jeffrey Epstein and the Bureau of Prisons’ policies and procedures; 2) any reports, witness statements, memorandum, and documents from any separate investigation conducted by the BOP; and 3) any reports, witness statements and/or documents created by any other federal agencies that investigated the circumstances surrounding the death of Jeffrey Epstein that have not already been disclosed.

¹ See, YouTube clip: https://www.youtube.com/watch?v=SI_haGuVBC4
² See, https://www.cnn.com/2019/09/11/us/jeffrey-epstein-investigation-us-marshals-documents/index.html
³ See, https://en.wikipedia.org/wiki/Death_of_Jeffrey_Epstein
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