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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
ease ask the Custodian of Records to provide a certificate of nonexistence of records. Also, following our conversation 1 received a voicemail from Lilly Ann Sanchez addressing the subpoenas. Since you have provided a written statement that you represent JEGE and Hyperion, I will assume that you alon
npersuaded by the letter and the presentation, but I agreed that I should carefully review transcripts of the recorded statements given to PBPD for Brady issues.15 Since witness credibility was clearly at the fore, I undertook efforts 14 The requested documents and items were never provided. 15 As th
those changes. Criminal Chief participated in numerous meetings on the case, and had private conversations regarding resolution of the matter with Lilly counsel to Mr. Epstein. Ms. had formerly served as Deputy Chief in the Major Crimes Section at the USAO while Mr. was Chief of Major Crimes. As
s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t
between his attorneys and your office, Epstein secretly withheld correspondence by several of his mostii ral owered attorneys — namely Ken Starr and Lilly. Sanchez. Epstein settled the case wit within days after this limited production, and we did not realize the absence of what must have been critic
npersuaded by the letter and the presentation, but I agreed that I should carefully review transcripts of the recorded statements given to PBPD for Brady issues." Since witness credibility was clearly at the fore, I undertook efforts " The requested documents and items were never provided. 15 As the
ntation of Epstein 12 8/4/2006 Victim Notification Letters 13 WI1/2006 Victim Notification Letters 14 1/17/07- 2/1/07 Correspondence between Lilly Ann Sanchez, Gerald Lelcourt, Andrew Laurie, A. Marie Villafrina, and John McMillan regarding 2/1/2007 Meeting 15 11/13/06- 1/22/07 Subpoenas to
r statements, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail
were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefeourt and Jay Lefkowitz had the opportunity to review and raise objections to the term
r statements, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail
were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the term
Entities connected to both Brady and Lilly

Jeffrey Epstein
PERSONAnn Sanchez
PERSON
United States
LOCATIONDarren Indyke
PERSON
Lesley Groff
PERSON
Joe Biden
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Bradley Edwards
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONJack Goldberger
PERSONGerald Lefcourt
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATIONRoy Black
PERSONJane Doe
PERSON