Epstein Secrets

Statute 905.27 disclosure that movant is aware of. 5. Personal notes of the Assistant State Attorney are work product and not discoverable. THEREFORE the State ofFlorida requests a Protective Order from this Honorable Court limiting the deposition and duces tecum to exclude notes, testimony, and materials which are a

n, finding nothing to suggest the withholding of evidence material to the appellant's guilt or to his punishment. The court also expressed doubt that Brady was intended to apply to testimony before a grand jury. In Jackman v. State, 140 So.2d 627 (Fla. 3d DCA 1962), appellant Jackman contended the trial

re providing ese no es o you. > > Thanks, and please feel free to give us a call to discuss. > > Original Message > From: Andrew Patel > Sent: Frida , December 20, 2019 8:15 AM > To: > Cc: Andrew Patel ; Jill Shellow ; Don Yannella > Subject: > Please send us a copy of the disclosure that yo

re. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not EFTA00100324 believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your eff

ore you file it, so that we can ensure that our position is accurately represented? Thanks very much. Original Message From: Andrew Patel Sent: Frida , December 20 2019 5:14 PM To: Cc: Jill Shellow Subject: RE: pstein We have attached a proposed disclosure cover letter that is modeled on a let

e the disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your eff

ation lilt suit pursuant to IX O.S.C. it 2255. Epstein will not contest the jurisdiction ill' the 11.5. District Coun her the StHAIRTI1 District of Plurida over his person and'or Ow subject mailer, and Epstein will not contest that the identified victims arc persons who, while minors, were victims of vi

statements, their credibility and the foundations. il' any. for claiming personal istiory. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the Ponta of prior inconsistent statements made by these women before they learned of any financial benefit that may be avai

04f2ca4f927ff4bffa31f=3F_e=jeeyacationVO40gmail.com&utm_source=ltera ble&utm_medium=email&utm=campaign=campaign_10628&noo=l&c3ch=Email&c3nid=10628> Frida Art Print ci=r> <http://d2c6Scykxd49oj.cloudfront.net/t?w=215&==215&zc=M&src=http://d1012Sbydnnt0.cloudfront.net/products/8 2118/squrre4wide/CIEl

fcf24bc98b7d2b6711b53ce6?_e=jeevacationVA0gmai=.com&utm_source=ltera ble&utm_medium=email&utm_campaign=campaign_10628=noo=l&c3ch=Email&c3nid=10628> Brady Console <http://links.dotandbo.com/u/f52cle6cafSe4857b6f70cfdddb27653=3F_e=jeevacation%40gmail.com&utmsource=lter able&utm_medium=email&utm=campaig

ATP-Jacksonville with her home address as Eps ein s 8 El Brillo Way, Palm Beach, Florida residence. While in Jacksonville, Cadillac SUV bearing Florid term lease from RAN Trust Florida. She resided at Jacksonville. drove a white, 2011 It is a short- oconut Creek, ring her stay in It appears

s representing 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 t

ed the case to Chapter? liquidation. Last year, l].S, Ba11kruptcy J udg~Lany Lessen Tule.d. that Abe and Lin Gosman's marri'age is invalid, because Floiida law does not recognize a Dominican Republic divorce that Lin Gosman tried to obtain from another man, Michael Castre. Thejudge's decisio11-was,a hu

CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very I familiar with it. It is analogous. It is a situation where there was trem

s it has identified. Because the information provided by these women goes directly to the question of Mr. Epstein’s guilt or innocence, it is classic Brady information. We understand that the U.S. Attorney might not want to disclose impeachment information about their witnesses prior to a charge or durin

he pertinent federal statutes, and respectfully request that the Office of the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While the

creates a substantive right which prevents prosecution and conviction of an individual after the statute has run.” See State v. King, 282 So. 2d 162 (Fla. 1973); Tucker v. State, 417 So. 2d 1006 (Fla. 3d D.C.A. 1982) (citing cases). Given the one-year statute of limitations, any conduct that might amou

e the disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your eff

that we are providing these notes to you. Thanks, and please feel free to give us a call to discuss. Original Message From: Andrew Patel Sent: Frida , December 20, 2019 8:15 AM To: Cc: Andrew Patel Jill Shellow Subject: ,.Epstein ; Don Yannella Please send us a copy of the disclosure that