Epstein Secrets

ca, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should app

PORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of A

ed that, when defense counsel elected to put his investigator on the witness stand at trial, he must turn over the investigator's report pursuant to Jencks, but defense counsel can redact the report to only disclose that portion of the report that relates to the investigator's testimony. 7 EFTA006001

ca, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should app

PORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ (DE941 The United States of A

ed that, when defense counsel elected to put his investigator on the witness stand at trial, he must turn over the investigator's report pursuant to Jencks, but defense counsel can redact the report to only disclose that portion of the report that relates to the investigator's testimony. 7 EFTA006570

t with the *226 defense by decid- ing after two years that it wanted a new ex- pert. Id. The court also denied as premature Fell's motion to exclude Weiner's testi- mony, holding that the nature and scope of Webees anticipated rebuttal testimony was unclear but that, even without interviewing Fell, hi

factors concerning sentencing." Id. Accordingly, the court declined to rule on admissibility prior to the government's disclosure of the scope of Weiner's projected testimony. Pursuant to the court's April 7 2005 or- der, Wetzel interviewed Fell and prepared a report explaining his findings. Fell, 2

statements of a witness on the subject of his testimony are the kind of evidentiary matter to which an adversary is entitled. F198. The Court in Jencks quoted the language of Mr. Clgef Justice Marshall in United State Burr, 25 Fed.Cas., No. 14,694, pp. 187, 191 (Va. 1807): "Now, if a paper be in

Non-Prosec tion Agreement, Mr. Epstein's defense team included Ken Start, Jay Lefkowitz, , Alan Dershowitz, Gerald Lefcourt, Roy Black, Guy Lewis, Martin Weinberg, Jack Goldberger, Stephanie Thacker', and the associates at Kirkland & Ellis who conducted research on discrete issues. This impressive legal team r

z, Gerald Lefcourt, Roy Black, Guy Lewis, Martin Weinberg, Jack Goldberger, Stephanie Thacker', and the ass

nts, their credibility and the foundations, if any, for claiming person! injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the tbnn of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

the case progresses. Michael C. Miller Martin G Weinberg EFTA00096247

se us promptly whether the government will be producing Brady material immediately even if it is contained in what might otherwise be considered as Jencks material, or whether you take the position that you arc not obligated to produce such material at this time. EFTA00096241 August 1, 2019 Page 11

n federal detention and bail law is: Hon. John L. Weinberg, Federal Bail and Detention Handbook (2003), whi

on probable cause, the court commonly will schedule a consolidated preliminary and detention hearing at which the prosecution must make available "Jencks" statements. If a hup://10.173.2.12/usao/cousa/olc/usaboolddrug/26drug.lum 4/10/2008 EFTA00191628 Federal Narcotics Prosecutions - Chapter 26 P

se us promptly whether the government will be producing Brady material immediately even if it is contained in what might otherwise be considered as Jencks material, or whether you take the position that you arc not obligated to produce such material at this time. EFTA00016145 --- PAGE BREAK --- Aug

the case progresses. Michael C. Miller Martin G Weinberg EFTA00016151