Epstein Secrets

l her as a prosecution witness, the government would have been obligated to disclose her prior exculpatory statements as impeachment material under Giglio v. United States, 405 U.S. 150 (1972). While petitioners attempt to rehabilitate Jane Doe 2 by relying upon theories of victimization, to explain h

those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te

rial. The government's assertion that it can withhold production of Accuser-4's prior statements because they are merely impeachment material under Giglio, and do not rise to the level of exculpatory material under Brady, is unsupported and flatly incorrect. (Opp. 20-22). The government admits that Ac

blunt the exculpatory significance of Accuser-4's omission; in fact, it underscores it. It is clear from the grand jury testimony of Special Agent Kuyrkendall that the FBI specifically asked Accuser-4 who scheduled her massage appointments 6 The government has provided only two quasi-Brady disclosures in t

l her as a prosecution witness, the government would have been obligated to disclose her prior exculpatory statements as impeachment material under Giglio v. United States, 405 U.S. 150 (1972). While petitioners attempt to rehabilitate Jane Doe 2 by relying upon theories of victimization, to explain h

those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te

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

By: Kuyrkendall B Nesbit Case ID #: 31E-MM-108062v/ Attn: SSA Date: 01/08/2010 From: Miami PB-1, Palm Beach County RA Contact: SA E. Nesb i ;tt Kuyrkendall, i----- Title: JEFFREY EPSTEIN; WSTA - CHILD PROSTITUTION Synopsis: To request transfer of above captioned case due to agent's transfer to anothe