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dge Bill Berger, also representing victims, called the agreement a "sweetheart deal." “Why was it so important for the government to make this deal?” Berger asked rhetorically. “We have not yet had ari honest explanation by any public official as to why it was made ... and why the victims were sold down t
andling of the 2006 charges and the civil suits that followed. 40. In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the Southern District of New York, Epstein was described as "a serial sexual predator who preyed on dozens of minor girls over a period of years." The letter emphasized that "the Gov
Bill Berger, also representing victims, called the agreement a "sweetheart deal." "Why was it so important for the government to make this deal?'' Berger asked rhetorically. "We have not yet had an honest explanation by any public official as to why it was made ... and why the victims were sold down
andling of the 2006 charges and the civil suits that followed. 37. In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the Southern District of New York, Epstein was described as “a serial sexual predator who preyed on dozens of minor girls over a period of years.” The letter emphasized that “the Gov
on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding
Page: EFTA00028937 →tor] is in a peculiar and very definite sense the servant of the law, the twofold aim of which is that guilt shall not escape or innocence suffer." Berger v. United States, 295 U.S. 78, 88 (1935). Moreover, "[i]n light of the prosecutor's public responsibilities, broad authority and discretion, the pr
Page: EFTA00028957 →01 --- PAGE BREAK --- Table of Authorities Cases Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (.=. Sept 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Marcel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical B
Page: EFTA00029102 →on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding
Page: EFTA00029108 →Entities connected to both Berger and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Jared Kushner
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Justin Trudeau
PERSONMartin Weinberg
PERSON
Bernie Madoff
PERSON
Julie K. Brown
PERSON
J. Robert Oppenheimer
PERSON
Marc Rich
PERSON
Michael Milken
PERSON
Bill Clinton
PERSONLeon Black
PERSON
Audrey Strauss
PERSON
Michael Cohen
PERSON
Alexander Acosta
PERSON
Denver
LOCATIONthe Securities and Exchange Commission
ORGANIZATION