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payments, promises of immunity, leniency, preferential treatment, or other inducements made to prospective Government witnesses, within the scope of Giglio vs. United States 405 U.S. 150 (1972), and Napue vs. Illinois 360 U.S. 264 (1959). E. The Government shall supply the defendant(s) with a record o
uez and to defeat any claim of "entrapment." None of the items contain any privileged information. The first item is a subpoena issued on behalf of the U.S. District Court and served by an attorney upon a non-party witness. The second items are a deposition that was attended by a number of attorneys representing parti
ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked Dexter and Marie t
sturbing, in terms of possible sex trafficking, was Epstein's relationship with owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, en alleged victim said that Epstein, Maxwell, and 'deliberately engaged in a pattem of racketeering that in
ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari
ms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel, owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, Maxwell, Brunel, Rodriguez, and "deliberately engaged in a pattern of r
1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio v. 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 th
8-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 54 of 54 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV- United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney Col
Entities connected to both Giglio and United States District Court

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATIONthe Southern District
LOCATION
Bradley Edwards
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Alexander Acosta
PERSONSouthern District
LOCATION
Alan Dershowitz
PERSON
Prince Andrew
PERSON
George W. Bush
PERSONRobert D. Critton
PERSONMaria Farmer
PERSON