4
Shared Docs
2
Same-Page
4 / 4
Mentions
ision series of the New York Times, concerning the same. In your letter, you cite Federal Rule of Evidence 16(a)(1)(E)(i), the Due Process Clause, Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), and their progeny. However, insofar as your request is premised on th
Page: EFTA00032753 →in the email enclosing your letter, the information you seek may constitute impeachment material of potential Government witnesses associated with Boies Schiller Flexner LLP ("BSF"), we understand it to be a request solely for impeachment material under Giglio and its progeny. As you are aware, the defendant is not enti
Page: EFTA00032753 →Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (S.D.N.Y. 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. Maxwel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.
islaine Maxwell submits this reply in support of her Motion to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. Introduction and Summary of the Argument If the government mea
islaine Maxwell submits this reply in support of her Motion to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. Introduction and Summary of the Argument If the government mea
Page: EFTA00028934 →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
Page: EFTA00028944 →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
Page: EFTA00029102 →islaine Maxwell submits this reply in support of her Motion to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. Introduction and Summary of the Argument If the government mea
Page: EFTA00029105 →Entities connected to both Brady and Boies Schiller Flexner LLP

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
David Boies
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
Giglio
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONSigrid McCawley
PERSON
George W. Bush
PERSON
Paul Cassell
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSON
Southern District of New York
ORGANIZATIONJeffrey Pagliuca
PERSONLeon Black
PERSONSecond Circuit
ORGANIZATION
Supreme Court
ORGANIZATION