This document is a formal legal letter dated August 1, 2019, from Jeffrey Epstein's defense counsel (Steptoe & Johnson LLP) to the U.S. Attorney's Office for the SDNY. The letter requests extensive discovery materials including the specific identities of 'dozens of minor girls' and 'employees' mentioned in the indictment, flight logs ('use of Mr. Epstein's planes'), massage schedules, and visitor logs. The defense also requests 'Brady material' (exculpatory evidence), specifically seeking evidence to support defenses that Epstein believed victims were over 18, that victims deceived him about their age, and that payments were gifts rather than for sex acts.
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