Epstein Secrets

return the attached stipulation to withdraw appeal we will file this when we get it back from you. Many thanks. Mike Michael C. Miller Partner Steptoe Ste a toe & Johnson LLP www.steptoe.com This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may

From: "Miller, Michael" < To: ' Cc: Reid" "Weingarten, "Lucas, Morgan" Subject: United States of America v. Epstein U.S. - 2nd Circuit Docket No. 19-2221 Date: Tue, 20 Aug 2019 14:56:58 +0000 Attachments: Draft_Stipulation_to_Withdraw_Appeal-c2.DOC 0 - If you can sign and return t

York United States Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE • JOHNSON LLP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that w

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use, For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reason

important to his defense. A source familiar with the facts confirmed that the company had sought the return of a copy of the laptop's contents that Steptoe had made, and that the laptop itself had already been returned. In mid-2018 after learning he was a target of the criminal investigation, Schwartz

utors' crackdown on insider trading. Level Global famously got its settlement with the Securities and Exchange Commission refunded after a favorable Second Circuit ruling EFTA00161666 set a higher bar for insider trading cases. That ruling also overturned Level Global co-founder Anthony Chiasson's conviction.

tes Courthouse (212) 805-6715 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe SttPtOt • JOHNSON ttP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use.' For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reaso

tes Courthouse (212) 805-6715 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe ATCPTOC A JOiiNSON ..n We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use.' For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reaso

1, 2019 By Electronic Mail orneys U.S. Attorney's Office for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Steptoe STEPTOE S .1(11.01CON I I Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for Particulars Discovery and Brady Material

ing a conversation with an agent or a witness is no less discoverable than if that same information were contained in an email." Id. Similarly, the Second Circuit has recognized that attorney proffers are equally subject to Brady obligations as witness proffers. States v. Triumph Capital Group, Inc., 544 F.3d

York United States Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE I JOHNSON UP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that w

of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use, For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee — not just reason

mim Michael C. Miller May 15, 2017 Brad Edwards, Esq. Re: v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: Steptoe stenos • JOHNSON 1.0 In accordance with the Court's May 15, 2017 Stipulation and Order in the above- referenced matter, defendants Jeffrey Epstein (

Corp., 711 F.3d 353, 359 (2d Cir. 2013) (Rule 9(b) "standard also applies to allegations of fraudulent predicate acts supporting a RICO claim"). As the Second Circuit explained: Rule 9(b) requires that, in alleging fraud or mistake, a party must state with particularity the circumstances constituting fraud or mis

2008 d. The instant prosecution was initiated as a result of undue political pressure. EFTA00016143 --- PAGE BREAK --- August 1, 2019 Page 9 Steptoe SWIGS • JOHns0is ur 6. Any documents or information that may serve to impeach any government witness, including but not limited to: a. Any docu

that attorney proffers are equally subject to Brady obligations as witness proffers. States V. Triumph Capital Group, Inc., 544 F.3d 149, 157, 165 (2d Cir. 2008) (recognizing that "[a]n attorney proffer apprises the government of what the client would be able to provide by way of testimony" and finding

"during a conversation with an agent or a witness is no less discoverable than if that same information were contained in an email." Id. Similarly, the Second Circuit has recognized that attorney proffers are equally subject to Brady obligations as witness proffers. States V. Triumph Capital Group, Inc., 544 F.3d