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From: ' To: ' Subject: RE: 2020.10.15 Notes re Call with Chiefs re Adams Disclosure Questions Date: Thu, 15 Oct 2020 23:51:41 +0000 This looks right to me. From: Sent: Thursday, October 15, 2020 5:35 PM To: Subject: 2020.10.15 Notes re Call with Chiefs re Adams Disclosure Questions Here are my notes of our call with the PC chiefs about some of the Adams disclosure issues I raised in an email. I've put the chiefs' responses to our questions in bold. Please supplement if you think I'm missing anything. 1) We seized two phones from Our plan is to produce the responsive materials in discovery, but wait to produce the full images of the phone until the 3500 deadline. Let us know if you think we should do something different. =thinks it is fine assuming we produce 3500 sufficiently far in advance of trial. We suggested 5 weeks in advance, which Ted says was fine. noted that we've been doing 8 weeks in advance for non-testifying 3500 and 4 weeks in advance for testifying 3500, so she thought this timing was appropriate. I noted that we're going to be marking conversations with Adams and about Adams and the incident on phone, so the defendant should already have the relevant materials. Chiefs said that sounded good. I said we're not going to be producing post-arrest recorded interview as Rule 16 but we will review it for Brady and produce it as 3500. Chiefs said that sounded good. 2) We obtained a search warrant relating to who is another woman that we believe Adams met at the MCC. The agents didn't execute the warrant. What is your view on whether we should produce it? On the one hand, the affidavit discusses Adams. On the other hand, producing it might undermine future investigative steps (like trying to renew and execute the warrant in the future). M aid he didn't think the unexecuted search warrant was Rule 16 or Brady, and that we should just include it as the agent's 3500. Bekah agreed and thought we should consider trying to do the warrant again. 3) We are going to review the limit number of 302s for statements that are arguably Brady. In light of the fact that some of these statements come from M, we're going to put these in a letter but not produce the 302 until 3500. Let us know if you agree, and what's your view on whether we should be naming the witnesses? said he's fine with that approach and they'll look at the letter. -recommended we just refer to the individuals as witness-1 and witness-2, etc., and that in the Parnas case we have some stock language that can be used. The chiefs said we should see if the Outlaw case got Outlaw's prison calls. They agreed we can just put defense on notice of the case but not produce materials from it. 4) As part of the Epstein death investigation, we interviewed several inmates and BOP personnel and it is possible that some of them may have mentioned Adams. Do you think we should be collecting these materials as future 3500? We plan on reviewing the MCC file for any documents related to Adams. EFTA00101093 We discussed reviewing the Noel/Thomas files for witness statements about Adams and producing anything that's potentially Brady. For those individuals, none of whom we plan to call, said we should just identify them as represented inmates but not provide names (at least until defense counsel asks). 5) have their contraband investigation. I think the overlap is minimal, but what do you view as our discovery obligations with respect to that investigation? Chiefs agreed we view it as a separate investigation and should put defense counsel on notice, but need not produce records from the separate case unless new info comes to light. We agreed to reach out to to see what, if any, overlap there is. EFTA00101094