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, for example, requested that the U.S. Attorney's Office provide to them unredacted copies of correspondence between the U.S. Attorney's Office and Jeffrey Epstein. Through civil discovery from Epstein, the victims have obtained half of that correspondence — the words written by the U.S. Attorney's Office — bu
ey's Office provide to them unredacted copies of correspondence between the U.S. Attorney's Office and Jeffrey Epstein. Through civil discovery from Epstein, the victims have obtained half of that correspondence — the words written by the U.S. Attorney's Office — but are lacking the other half — the wor
spondence between the U.S. Attorney's Office and Jeffrey Epstein. Through civil discovery from Epstein, th
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United States. Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States, Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin
spondence between the U.S. Attorney's Office and Jeffrey Epstein. Through civil discovery from Epstein, th
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
, for example, requested that the U.S. Attorney's Office provide to them unredacted copies of correspondence between the U.S. Attorney's Office and Jeffrey Epstein. Through civil discovery from Epstein, the victims have obtained half of that correspondence — the words written by the U.S. Attorney's Office — bu
ey's Office provide to them unredacted copies of correspondence between the U.S. Attorney's Office and Jeffrey Epstein. Through civil discovery from Epstein, the victims have obtained half of that correspondence — the words written by the U.S. Attorney's Office — but are lacking the other half — the wor
may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United States. Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States, Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin
necessary" (doc. #17 at I). The Office asserted that the Court need only take judicial notice of the fact that no indictment had been filed against Epstein to resolve the case. On August I, 2008, the victims filed a response to the Government's "Notice" (doe. #19), giving a proposed statement of facts
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United Stales, Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States' Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin
se to your letter dated December 2, 2019, which requests certain information in light of a New York Times article dated November 30, 2019 concerning Jeffrey Epstein and alleged videos, and Episode 22 of The Weekly, a television series of the New York Times, concerning the same. In your letter, you cite Federal
Page: EFTA00032753 →ticle dated November 30, 2019 concerning Jeffrey Epstein and alleged videos, and Episode 22 of The Weekly,
Page: EFTA00032753 →Times article dated November 30, 2019 concerning Jeffrey Epstein and alleged videos, and Episode 22 of Th
Page: EFTA00032753 →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
Page: EFTA00032753 →trict of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative agencies — and Mr. Epstein's attorneys. b. All communications between and among any government employees including, but not limited to, attorneys and staff at the U.S. Attorn
Page: EFTA00011419 →r federal and state investigative agencies — and Mr. Epstein's attorneys. b. All communications between and a
Page: EFTA00011419 →the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communicatio
Page: EFTA00011419 →s between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings that took place in or about 2016 in whi
Page: EFTA00011421 →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
Page: EFTA00011422 →Office for the Southern District of New York New York, New York 10007 Dear Steptoe STEPTOE S .161411SON II August 1, 2019 Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for Particulars Discovery and Brady Material We arc writing on behalf of Jeffrey Epstein regarding discovery i
Page: EFTA00016136 →for Particulars Discovery and Brady Material We arc writing on behalf of Jeffrey Epstein regarding discovery in this case. In order to preserve Mr. Epstein's rights, arid to request additional information, we respectfully submit this formal request for discovery in this case pursuant to the Fourth, Filt
Page: EFTA00016136 →ing discovery in this case. In order to preserve Mr. Epstein's rights, arid to request additional information,
Page: EFTA00016136 →1411SON II August 1, 2019 Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for
Page: EFTA00016136 →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
Page: EFTA00016142 →Entities connected to both Jeffrey Epstein and Agurs
Leon Black
PERSON
Prince Andrew
PERSON
Woody Allen
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
Scarlett Johansson
PERSON
Geoffrey S. Berman
PERSONCourtney Wild
PERSON
David Boies
PERSONFISTOS & LEHRMAN
ORGANIZATIONJoseph L. Ackerman
PERSON
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATION