Epstein Secrets

ced to Mr. Epstein. F. Finally, Mr. Epstein notes Rule 4.C.3 of Judge Berman's Individual Practices, which, inter alia, (1) requires disclosure of Brady materials within two weeks of its discovery; (2) re-affirms that the government's obligation applies "regardless of whether the Government 'credits

k 10007 Steptoe STEPTOE S .1(11.01CON I I Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for Particulars Discovery and Brady Material Dear Ms. Comey, Ms. Moe, and Mr. Rossmiller: We arc writing on behalf of Jeffrey Epstein regarding discovery in this case. In order to pr

d to the Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), and the Department of Homeland Security. In addition, such information includes information in EFTA00096232 August 1, 2019 Page 2 Step

spaper urging congressional approval of a ban. "I'm a member of the NRA. And my position on the right to bear arms is well known. But I support the Brady bill and I urge the Congress to enact it without delay. It's just plain common sense that there be a waiting period (7 days) to allow local law enfo

easts and other claims that might come along doesn't put much of a dent in the company's financials. As Johnson & Johnson declared in a filing with the Securities and Exchange Commission three weeks before the analysts' conference, "In the Company's opinion ... the ultimate outcome of legal proceedings, net of liabilities accrued in

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

8 WL 3956494, at *4-.5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

18 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

18 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

18 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

he Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. The Government's Rul

18 WL 3956494, at *4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury present

d to the Department of Justice (including but not limited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), and the Department of Homeland Security. In addition, such information includes information in EFTA00016136 --- PAGE BREAK --- August 1

entify the "other" overt acts ("the following overt acts, among others") referenced in ¶ 22 of the indictment. IV. Brady Material A. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976)