Epstein Secrets

ned the Office of Independent Counsel Daniel S. Pearson, who conducted the investigation of then-Commerce Secretary Ronald H. Brown. After Secretary Brown died and Independent Counsel Pearson closed his investigation, Mr. Biran became a Trial Attorney in the Public Integrity Section at the Justice Dep

nunc pro tunc to disclose to Mr. Biran matters occurring before the grand jury, and enter a protective order. 18. In addition to the issue of the Response, during the OPR interview, must be able to explain the origins of the grand jury investigation, how it progressed, and how it continued even after

nvestigation of U.S. Secretary of Commerce Ronald Brown; the U.S. Attorney's Office for the Eastern Dist

exhibit list ("Exhibit List"), and 234 exhibits ("Exhibits"). These were all provided to OPR on May 10, 2019. Mr. Biran was provided a copy of the Response and a redacted version of the Chart.3 He was not provided the other items, that is, the Timeline, the Exhibit List, or the Exhibits. 3 All victim i

3 KMK JCF, 2006 WL 2664313 (S.D.N.Y. Sept. 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Maxwel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994) 14, 18, 19 Elkins v. United S

I. The Government's Response to Maxwell's Motion. Confronted with evidence of AUSA misrepresentations to Judge McMahon, the government has filed a Response reluctantly admitting that the U.S. Attorney's Office had sustained contact with Boies Schiller in 2016. Even so, the government tries its best to m

ty.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp., 116 F.R.D. 205, 210 (

he litigant standing to challenge the validity of that subpoena." In re Grand Jury, Ill F.3d 1066, 1073 (3d Cir. 1997)(collecting On page 38 of its Response, the government finally admits what it is looking for: evidence of sexual exploitation of minors, including surveillance camera footage, "computer p