Epstein Secrets

ented (Epst4in's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others were.) Our understanding is that his repr

knowing 26:25 38:5 knowledge 5:13 13:11 known 21:4 32:14 knows 11:3 13:2 L lack 41:22 ladies 20:23 21:3,20 Lake 124 language 18:14 32:11 LARRY 2:21 44:21 Las 1:17 last 33:22 41:24 Lauderdale 1:18 2:16 law 7:1 27:24 28:9 lawsuit 25:18,19 lawsuits 30:17 lawyers 821 9:4,7 10:23,23 17:2

Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxbur

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

ented (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed but the others were.) Our understanding is that his repr

. 17 MARTIN G. WEINBERG, ESQ. 18 20 Park Plaza Boston MA 02116 19 (Via telephone) 20 JAY LEFKOWITZ, ESQ. (via telephone) 21 REPORTED BY: LARRY HERB RPR-RMR-FCRR-AE 22 Official United States Court Reporter Federally Certified Realtime Reporter 23 400 North Miami Avenue, Room 8N09 Miami

Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxbur

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

-02753528 Additional records — attached as Exhibit D EFTA00099022 November 8, Page 3 5. Shopper's Travel records SDNY GM 00006061-00006079 6. Larry Visoski flight manifests SDNY_GM_00405330-00405565 SDNY GM 00405788-00405969 7. General Release, Epstein Victims' Compensation Program Attached as Exhibi

avel records SDNY GM 00006061-00006079 6. Larry Visoski flight manifests SDNY_GM_00405330-00405565 SDNY

ent requests which the defense may want to use in any case-in-chief. Third, the government is still producing Rule 16 discovery, 3500 material, and Giglio material, which may require additional investigation and may, in turn, yield additional documents that the defense may wish to use in any case-in-ch

s Confidential SDNY_GM_00010460 SDNY_GM_000 10461 Verizon records Confidential SDNY GM 00010462 SDNY_GM_000 11483 Flight manifest records from Lawrence Visoki Confidential SDNY_GM_000 11484 SDNY_GM_000 11488 Western Union record of no accounts found Confidential SDNY_GM_00011489 SDNY_GM_00012474 SDNY_

The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by the Court.