EFTA00032751

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LAW orFucts SCOTT A. SREBNICK, P.A. SCOTT A. SREBNICK' , ALSO ADMITTED IN NEW YORK December 2, 2019 United States Attorney's Office Southern District of New York One Saint Andrew's Plaza New York, NY 10007 Re: United States v. Michael Avenatti Case No. Si 19 Cr 373 (PGG) Gentlemen: 201 S. Biscayne Boulevard Salle 1210 Miami, Florida 33131 Tel 305-285-9019 Far 305-377-9937 sco0€'srcbnicklawcom write subakklatecom On behalf of Mr. Avenatti, we make the request below pursuant to Rule 16(a)(1)(EXi) and the government's obligations under the Due Process Clause, Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), and their progeny. This request is meant to direct the government's attention to specific evidence. It is not intended to be a substitute for general categories of evidence that the government is otherwise required to produce under the Due Process Clause and the above authorities (e.g., plea agreements, deferred prosecution agreements, non-prosecution agreements, promises and benefits to witnesses, threatened charges against witnesses, etc.), all of which we request as well. On Saturday, November 30, 2019, the New York Times ("Times") published an investigative report entitled "Jeffrey Epstein, Blackmail, and a Lucrative 'Hot List'." See httns://www.nvtimes.com/2019/11/30/business/david-boies-pottinger-ieffrev -eostein- videos.html. The Times reported about an agreement between David