Epstein Secrets

ence that tends to exculpate the accused, but also evidence that is useful to impeach the credibility of a government witness," id., also known as "Giglio material," as well as any statements of witnesses "which are contradictory or inconsistent with the government's theory of the case." United States

he government's theory of the case." United States v. Harris, No. 00 Cr. 105 (RPP), 2000 WL 1273720, at *2 (S.D.N.Y. Sept. 7, 2000) (citing Kyles v. Whitley, 514 U.S. 419 (1995). 2. Rule 16 Rule 16 provides, in pertinent part: Upon a defendant's request, the government must permit the defendant to in

ep't of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dept of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. 1 (2001) 26, 27 Giglio v. United States, 405 U.S. 150 (1972) In re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E.

ed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) 15 Kyles v. Whitley, 514 U.S. 419 (1995) 19 N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975) 26 Nat'l Res. Del Council v. United States Ening. Prot. Agency, 954

dy requests." As an initial matter, we take seriously our disclosure obligations, including those arising under Rule 16, Brady and its progeny, and Giglio v. United States, 405 U.S. 150 (1972) and its progeny, and we intend to comply fully with those obligations. We intend to do so irrespective of whe

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

t of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dep't of Interior v. Klamath Water Users Protective Ass 'it, 532 U.S. 1 (2001) 26, 27 Giglio v. United States, 405 U.S. 150 (1972) In re Sealed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E.

ed Case, 121 F.3d 729 (D.C. Cir. 1997) passim 26 In re Terrorist Bombings of U.S. Embassies in E. Africa, 552 F.3d 93 (2d Cir. 2008) 15 Kyles v. Whitley, 514 U.S. 419 (1995) 19 N.L.R.B. v. Sears, Roebuck & Co., 421 U.S. 132 (1975) 26 Nat'l Res. Def. Council v. United States Envtl. Prot. Agency, 95

and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search for, locate, i

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 (