Epstein Secrets

thers") referenced in ¶ 22 of the indictment. IV. Brady Material A. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitne

ial A. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practic

ncerning the same. In your letter, you cite Federal Rule of Evidence 16(a)(1)(E)(i), the Due Process Clause, Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), and their progeny. However, insofar as your request is premised on the proposition that, as you stated in th

cution team (which is not on any Jeffrey Epstein-related investigation) both had it and was at liberty to provide it. See generally United States v. Agurs, 427 U.S. 97, 109 n.16 (1976). We also note that Scott Wilson, Esq. has moved from BSF to DLA Piper. Notwithstanding this view, we are available to

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio. United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law the

t which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment inf

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio. United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law the

t which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment inf

evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agurs, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We request all such evidence requested above and e

ulted by Mr. Epstein, with or without the involvement of Ms. Maxwell, had a financial motive or incentive to accuse Mr. Epstein or Ms. Maxwell. 6. Giglio Information: Pursuant to Giglio v. United States, 405 U.S. 150 (1972), we request dates and descriptions of any and all considerations or promises (