Epstein Secrets

e foregoing requests with you when convenient. We reserve the right to request further discovery and additional particulars as the case progresses. Michael C. Miller Martin G Weinberg EFTA00096247

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

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 accordan

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

Michael C. Miller 1114 Avenue of the Americas New York. NY 10036 main www.steploe.com May 2017 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Le

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

Michael C. Miller New York. NY 10036 main anewsteptce.com By Electronic Mail Assistant United States Attorneys U.S. Attorney's Office for the Southern District

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