Epstein Secrets

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

eral charges that limited Epstein's sentencing exposure . . . " See Tab 1, May 19, 2008 Letter from J. . In fact, by a email dated August 3, 2007, Criminal Division Chief Matthew Menchel advised the defense that the federal government required a minimum term of two years of incarceration. See Tab 40, August 3,

each was astonished that any evidence Ms. Villafana purported to have was not shared with the State or made available to Mr Epstein's attorneys as Brady evidence. Ms. Villafana launched a totally unsupportable and vastly overreaching sex trafficking investigation without providing notification to th

hat her subpoena sought.' As a weak explanation of the many complaints about Ms. Villafana's misconduct and her flagrant violations of the USAM, her Criminal Division Chief, Matthew Menchel, eventually characterized her as "unsupervisable." In August 2007, Ms. Villafana demanded that, in exchange for a deferral o

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

our review of this case is limited both factually and legally. We have not looked at the entire universe of facts in this case. It is not the role of the Criminal Division to conduct a complete factual inquiry from scratch.” (CEOS letter at p. 1). Indeed, entire subject areas relevant to the inquiry were not considered

de v. McLaughlin, 500 U.S. 44, 52-58 (1991) (defining "prompt" under Gerstein's requirement of a prompt judicial determination of probable cause). 6 Brady v. Maryland, 373 U.S. 83, 86 (1963) (holding prosecution's withholding of the confession of defendant's confederate violated defendant's due process

to be particularly successful. '°? The federal government seems to share that view. The Justice Department created a Public Integrity Section within the Criminal Division in 1976, !>4 and in the four decades since, federal prosecutors have [*893] aggressively prosecuted conduct of state and local officials that it det

lso United States v. Ruiz, 536 U.S. 622, 629 (2002) (quoting Weatherford, 429 U.S. at 559). 298 Wardius v. Oregon, 412 U.S. 470,474 (1973). 299 See Brady v. Maryland, 373 U.S. 83, 87 (1963). 300 See United States v. Bagley, 473 U.S. 667, 675 (1985). 301 United States v. Garrett, 238 F.3d 293, 302 (St

rime victims rights representative. See CVRA Subcommittee Memo, supra note 66, at 1 (noting that Deborah Rhodes, Counselor to the Asst. Atty. Gen. of the Criminal Division, served on the subcommittee drafting this language). 416 At another point in its memorandum, the CVRA Subcommittee refers to /8 U.S.C. § 3771(d)(6),

d AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Sealed) EXHIBIT N: Emails between AUSA and AUSA and other AUSAs (Nov. 30, 2018—Dec. 6, 2018) (Sealed) EXHIBIT O: Email from Sta

l filed her Motion, she did not have access to the government's emails and AUSA contemporaneous notes, despite their obvious exculpatory value. See Brady v. Maryland, 373 U.S. 83, 87-88 (1963). The government did not disclose these materials until Maxwell challenged the government's candor and conduc

ses Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (.=. 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. Marcel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 19

d AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Sealed) EXHIBIT I: Emails between AUSA and AUSA and other AUSAs (Nov. 30, 2018—Dec. 6, 2018) (Sealed) EXHIBIT O: Email from Sta