Epstein Secrets

EFTA00103933 27 JaRsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very familiar with it. It is analogous. It is a situation where there was tr

aw and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense ag

e 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN DISTRICT REPORTERS, P.C. EFTA00103914 8 J8RsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

EFTA00106110 27 JaRsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very familiar with it. It is analogous. It is a situation where there was tr

aw and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense ag

e 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN DISTRICT REPORTERS, P.C. EFTA00106091 8 J8RsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

EFTA00076210 27 J8RsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very familiar with it. It is analogous. It is a situation where there was tr

aw and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense ag

e 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN RS, P.C. EFTA00076191 8 J8RsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

EFTA00077437 27 JaRsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very familiar with it. It is analogous. It is a situation where there was tr

aw and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense ag

e 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN DISTRICT REPORTERS, P.C. EFTA00077418 8 J8RsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

EFTA00080185 27 JaRsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very familiar with it. It is analogous. It is a situation where there was tr

aw and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense ag

e 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN DISTRICT REPORTERS, P.C. EFTA00080166 8 J8RsEPS1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very I familiar with it. It is analogous. It is a situation where there was trem

f law and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. In a case called United States v. Heaton, H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense again

Rule 48. I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in Heaton. I believe it is SOUTHERN DISTRICT REPORTERS, P.O. (212) 805-0300 i i CA/Aronberg-000926 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/20

withhold relevant information contrary to its position in court. In their motion (at pp. 5-9), the victims explained why fairness entitles them to "Brady" information (i.e., information contradicting the Government's position) no less than criminal defendants. In response, the Government does not eve

atute in favor of interpretations that promote victims' interest in fairness, respect, and dignity." 2008 WL 501321 at *15; accord United States v. Heaton, 458 F.Supp.2d 1271, 1272 (D. Utah 2006). 9 EFTA00178065 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 10 of 29 att

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

arges are filed). Another district court refused prosecutors' request to dismiss charges before the prosecutor consulted the victim. United States v. Heaton 458 F. Supp. 2d 1271, 1272 (D. Utah 2006) (citing victim's right under 78 U.S.C. § 3771](a)(8) "to be treated with fairness and with respect for [her

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

In re Richards, 213 F.3d 773, 787 (3d Cir. 2000); see also United States v. Hamm, 659 F.2d 624, 629-30 (Sth Cir. 1981). 417 Accord United States v. Heaton, 458 F. Supp. 2d 1271, 1272 (D. Utah 2006). 478 Black's Law Dictionary 633 (Bryan A. Garner ed., 8th ed. 2004) (defining the adjective "fair"). 479