Epstein Secrets

torney's Office. Also consistent with the October 7, 2020 letter, we have taken the following steps to obtain additional agency files to review for Brady, Giglio, and Jencks Act material. First, we have confirmed with the U.S. Attorney's Office in Georgia that it does not possess any substantive witn

uring our investigation. To date, our team has not identified any photographs of among those seized. 7 As discussed below, we have identified one FedEx invoice from 2002 reflecting a package sent from Epstein's business address in Manhattan to home address in 2021.01.26 EFTA 00023125 EFTA0273123

led receiving multiple gifts from Epstein. received multiple s of lingerie orm Victoria's Secret, which were shipped to her home by either UPS or FedEx. had a New York address.? She also reca recalls seeing that the return address for these packages s that the packages either had Epstein's or Maxw

d Order a Bill of Particulars as to Counts Five and Six. 22 VII. The Court Should Order the Government to Produce Accuser-4's Prior Statements as Brady Material 24 VIII. Ms. Maxwell Incorporates All of the Arguments Raised in Her Initial Pretrial Motions and Reasserts Them as to the S2 Indictment

s Five and Six, were presented to both grand juries. Furthermore, the proof offered to corroborate Accuser-4's allegations—e.g., cell phone records, FedEx records, message pad notes, etc.—was identical. (See Ex. C at 56:21-57:10). The chart below highlights these similarities: S2 Indictment SDFL Gra

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 dur

0-8711 (561) 820-8777 (Fax) NUMBER OF PAGES, INCLUDING THIS PAGE: 2- COMMENTS: Original document: To follow via regular mail To follow via Federal Express To follow via hand delivery )c Nothing to follow, FAX = original 2 08-80736-CV-MARRA RFP IMPS 001700 EFTA00209879 U.S. Department of Jus

nnsylvania, which spent $2 million to repair damage by the malware, U.S. Attorney Scott Brady said at a Monday news conference in Washington, D.C." Brady "and other officials said the Russian officers are part of the same unit that the Justice Department said attempted to disrupt the 2016 election and

arly $1 billion in losses to three victims alone that are mentioned in the indictment. In addition to Heritage Valley, they are TNT Express B.V. (a FedEx subsidiary) and an unnamed U.S. pharmaceutical maker that paid $500 million to fix the damage." Politico <https://www.politico.com/news/2020/10/19/r

nnsylvania, which spent $2 million to repair damage by the malware, U.S. Attorney Scott Brady said at a Monday news conference in Washington, D.C." Brady "and other officials said the Russian officers are part of the same unit that the Justice Department said attempted to disrupt the 2016 election and

early $1 billion in losses to three victims alone that are mentioned in the indictment. In addition to Heritage Valley, they are TNT Express B.V. (a FedEx subsidiary) and an unnamed U.S. pharmaceutical maker that paid $500 million to fix the damage." Politico (10/19, Geller, 4.29M) reports, "As office

cy's Agent Name and Telephone Number: CHECK ALL THAT APPLY: This case involves TRIOGERLOCK Defendant(s) Offense discovered as results of (NICS) Brady __Yes No This case involves Victim(s) _ Non Government Witnesses or both. Forfeiture of Assets may be Involved. OCDETF Case Operation Name:

. If you have any questions or concerns, please feel free to contact me. Thanks! Original document: To follow via regular mail To follow via Federal Express To follow via interagency mail To follow via hand delivery To follow via email X Nothing to follow, FAX = original 1 1 EFTA00223937

's Agent Name and Telephone Number: cell trarcx-ALL-TrarAPPLY: This case involves TRIGGERLOCK Defendants) Offense discovered as results of (NICS) Brady Yes No This case involves Victim(s) _ Non Government Witnesses or both. Forfeiture of Assets may be involved. OCDETF Case Operation Name:

#. If you have any questions or concerns, please feel free to contact me. Thanks! Original document: To follow via regular mail To follow via Federal Express To follow via interagency mail To follow via hand delivery To follow via email X Nothing to follow, FAX = original EFTA00187113 SOUTHERN

y's Agent Name and Telephone Number: LIM ICATCTRA APPLY. cell This case involves TRIGGERLOCK Defendant(s) Offense discovered as results of (NICS) Brady Yes No This case involves Victim(s) _ Non Government Witnesses or both. Forfeiture of Assets may be involved. OCDETF Case Operation Name: OC

S #. If you have any questions or concerns, please feel free to contact me. Thanks! Original document: To follow via regular mail To follow via Federal Express To follow via interagency mail To follow via hand delivery To follow via email X Nothing to follow, FAX = original EFTA00187123 EX PERT

igate crimes with which the defendant is not charged. Moreover, the defense's most recent letter refers to these materials as somehow constituting Brady material without any explanation of what information within the most recent production is supposedly exculpatory. But given that, as noted above, a

claims 4 The Government understands from defense counsel that the CD containing a copy of this production, which the Government sent to the MDC via FedEx overnight shipping last week, has not been provided to the defendant. The Government has repeatedly asked MDC legal counsel to locate this CD and p

nnsylvania, which spent $2 million to repair damage by the malware, U.S. Attorney Scott Brady said at a Monday news conference in Washington, D.C." Brady "and other officials said the Russian officers are part of the same unit that the Justice Department said attempted to disrupt the 2016 election and

early $1 billion in losses to three victims alone that are mentioned in the indictment. In addition to Heritage Valley, they are TNT Express B.V. (a FedEx subsidiary) and an unnamed U.S. pharmaceutical maker that paid $500 million to fix the damage." Politico (10/19, Geller, 4.29M) reports, "As office