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, their credibility and the foundations. il' any. for claiming personal istiory. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the Ponta of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to th
gerated claims once they are inlbnned of Mr. Epstein's waiver under Section 2255 for the settlement of claims pursuant to the Agreement. Indeed, Mr. Whitley states. " . . .the Department [of Justice] should consider developing processes and procedures to ensure that the investigative process is insulate
nts, their credibility and the foundations, if any, for claiming person! injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the tbnn of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the
e Agreement, the SDFL unilaterally proposed to divest its right to select the attorney representative for the victims. Contrary to Messrs. Starr and Whitley's recent assertion that this was "engineered in a way that appears intended to profit particular lawyers in private practice in South Florida with
fic requests (the "Requests"). The letter also makes a general request for materials pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419 (1995), followed by 10 "specific Brady requests." As an initial matter, we take seriously our disclosure obligations, including those
Page: EFTA00030569 →(S.D.N.Y. Jan. 6, 2010) (declining to order immediate disclosure of Giglio material, because the Government stated it would provide both Giglio and Jencks Act material "shortly before trial"); United States v. Davis, No. 06 Cr. 911 (LBS), 2009 WL 637164, at *14 (S.D.N.Y. March 11, 2009) ("The Second C
Page: EFTA00030570 →Entities connected to both Jencks and Whitley

Jeffrey Epstein
PERSON
United States
LOCATIONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
Brady
PERSONRoy Black
PERSONGerald Lefcourt
PERSON
Jay Lefkowitz
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
A. Marie Villafana
PERSON
Ken Starr
PERSON
Joe Biden
PERSONAnn Sanchez
PERSON
George W. Bush
PERSON
Barry Diller
PERSON