Epstein Secrets

omien/dufarticle.asp7NAPC=S&AccessionNo=PBDN000020080315e43e00007 • New York Law Journal, MEDIA Article,United States,Headline:6081. PEOPLE, res, v. JEFFREY E. EPSTEIN. def-ap; DECISIONS: First Judicial Department; Appellate Division. http://global.factiva.com/enklutarticle.asp?NAPC=S&AccessionNo=NYLJ000020111129e7

y: Critical Alert ID: 15748113.11639831.83945295 Entity Information Entity ID: 83945295 Riskid: R12818110 Entity Name: Jeffrey Epstein Alias: • JEFFREY EDWARD EPSTEIN • Jeffery Epstein Address: • 9 E 71ST ST, NEW YORK, New York, 10021-4102, UNITED STATES • 6100 RED HOOK QUARTER, B3, ST THOMAS, Virgin Islands. 00

, Mississippi) • 1954 • 1/20/1953 president of J Epstein & Co. Blue Grey 600" White Case No: 0809381

icle,United States,Headline:6081. PEOPLE, res, v. JEFFREY E. EPSTEIN. def-ap; DECISIONS: First Judicial Depa

icle,United States,Headline:6081. PEOPLE, res, v. JEFFREY E. EPSTEIN. def-ap; DECISIONS: First Judicial Depar

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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

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

the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communicatio

r federal and state investigative agencies — and Mr. Epstein's attorneys. b. All communications between and a

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. Agars, 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

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

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

the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communicatio

r federal and state investigative agencies — and Mr. Epstein's attorneys. b. All communications between and a

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. Agars, 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

the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communicatio

r federal and state investigative agencies — and Mr. Epstein's attorneys. b. All communications between and a

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

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

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. Agars, 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

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

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

the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communicatio

r federal and state investigative agencies — and Mr. Epstein's attorneys. b. All communications between and a

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. Agars, 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

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

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

the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communicatio

r federal and state investigative agencies — and Mr. Epstein's attorneys. b. All communications between and a

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. Agars, 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

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

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

the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communicatio

r federal and state investigative agencies — and Mr. Epstein's attorneys. b. All communications between and a

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. Agars, 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

nted. Continental Casualty Co.'. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008, in Florida circuit court. I k was sentenced by the state court, and has served his sentence. Individuals

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 States. Agars, 427 U.S. 97 (1976)." See, eg., Standing Discovery Order, United States. Enriquex, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standing

ay, the Court entered an order granting the victims' motion to compel and directing the Government to produce (1) all correspondence between it and Epstein; (2) all communications between the Government and outside entities; and (3) every other document requested by the victims. DE 190 at 2. With respe

to the issue. As another illustration, consider the victims' request for information about former prosecutor personal business relationship with Jeffrey Epstein. See, e.g., Victims' First RFP's at 1 16(f). Here again, the victims know that the Government possesses such information, because it admitted to ha

prosecutor personal business relationship with Jeffrey Epstein. See, e.g., Victims' First RFP's at 1 16

be favorable to the defendant on the issues of guilty or punishment within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and United States v. Agars, 427 U.S. 97 (1976)." The Court should adopt that language to the case at hand here. Interesting, the Standing Discovery Order — and associated loc

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