Epstein Secrets

ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving a defendant who, despit

en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows a history that is both highly unusual and deeply troubling. The gov

ohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

States v. Mozer, 828 F. Supp. 208 (S.D.N.Y. 1993) 12 iii EFTA00065992 United States v. Papa, 533 F.2d 815 (2d Cir. 1975) 29 United States v. Persico, 620 F. Supp. 836 (S.D.N.Y.), aff'd, 774 F.2d 30 (2d Cir. 1985) 22 United States v. Prisco, 391 F. App'x 920 (2d Cir. 2010) 22 United States v.

ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving I defendant who, despit

en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows I history that is both highly unusual and deeply troubling. The gov

overnment has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimat

States v. Mozer, 828 F. Supp. 208 (S.D.N.Y. 1993) 12 iii EFTA00099355 United States v. Papa, 533 F.2d 815 (2d Cir. 1975) 29 United States v. Persico, 620 F. Supp. 836 (S.D.N.Y.), aff'd, 774 F.2d 30 (2d Cir. 1985) 22 United States v. Prisco, 391 F. App'x 920 (2d Cir. 2010) 22 United States v.

200 (2d Cir. 1995) United States v. Pelull°, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United States v. Persico, 645 F.3d 85 (2d Cir. 2011) 8 21 10 8 United States v. Reese, 933 F. Supp. 2d 579 (S.D.N.Y. 2013) 13, 16 United States v. Rigas, 258 F. Supp.

s at DOJ-OIG tasked with preparing this report, the Government understands that the report will likely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 EFTA00027315 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 10 of 34 written state

ely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 EFTA

tensive attack by reason of other evidence, the undisclosed evidence may properly be viewed as cumulative, and hence not material." United States v. Persico, 645 F.3d 85, 111 (2d Cir. 2011) (citing cases). With regard to the timing of disclosing material under Giglio, the Second Circuit, in Coppa, rejec

200 (2d Cir. 1995) United States v. Pelullo, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United States v. Persico, 645 F.3d 85 (2d Cir. 2011) 8 21 10 8 United States v. Reese, 933 F. Supp. 2d 579 (S.D.N.Y. 2013) 13, 16 United States v. Rigas, 258 F. Supp.

s at DOJ-OIG tasked with preparing this report, the Government understands that the report will likely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 EFTA00031271 --- PAGE BREAK --- written statements, photos, videos, and incident reports created, manufacture

ely focus on the events surrounding the death of Jeffrey Epstein and BOP policies and procedures. 4 EFTA

the Indictment relates to a 14-hour time period); count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein's suicide; internal MCC phone records; employee files and staffing history for Noel and Thomas; and a wide range of written Bureau of prison polici