Epstein Secrets

e the disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not believe that this is in fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video evidence. While we applaud your eff

Jill Shellow Subject: RE: pstein We have attached a proposed disclosure cover letter that is modeled on a letter sent by the Government in United States v. Madonna, 17 Cr. 89 (CS). We have also attached proposed redacted disclosures. As you and I discussed, we offer this as a means to ensure our client'

charges are sufficiently specific. • Maxwell moves to compel the Government to produce the statements of "Minor-Victim 4" in the S2 indictment as Brady material. The Court concludes that the current disclosure schedule gives Maxwell sufficient time to make effective use of any such statements and t

pare for trial, to prevent surprise, and to interpose a plea of double jeopardy should he be prosecuted a second time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). "The purpose of a bill of particulars is to supplement the allegations in the indictment when necessar

ugh to inform the defendant of the charges and allow the defendant to plead double jeopardy in a later prosecution based on the same events. United States v. Stavrouiakis, 952 F.2d 686, 693 (2d Cir. 1992). "Under this test, an indictment need do little more than to track the language of the statute charge

nfer on an overall schedule for all remaining pretrial disclosures. A. The Court accepts the Government's representations that it has disclosed all Brady and Giglio Material The Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963) and Giglio v. United States, 405 U.S. 150 (1972) require