Epstein Secrets

ced to Mr. Epstein. F. Finally, Mr. Epstein notes Rule 4.C.3 of Judge Berman's Individual Practices, which, inter alia, (1) requires disclosure of Brady materials within two weeks of its discovery; (2) re-affirms that the government's obligation applies "regardless of whether the Government 'credits

k 10007 Steptoe STEPTOE S .1(11.01CON I I Re: United States v. Jeffrey Epstein. No. 19-cr-00490 Defendant's Request for Particulars Discovery and Brady Material Dear Ms. Comey, Ms. Moe, and Mr. Rossmiller: We arc writing on behalf of Jeffrey Epstein regarding discovery in this case. In order to pr

mited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), and the Department of Homeland Security. In addition, such information includes information in EFTA00096232 August 1, 2019 Page 2 Steptoe SOPPIOa . JOHNSON LLP the possession, custod

en the Department of Justice and Mr. Epstein (the "NPA"). Each is subject to disclosure pursuant to the government's obligations under, inter alia. Brady v. Maryland, 373 U.S. 83 (1963) and the Federal Rules of Criminal Procedure. Mr. Epstein seeks all documents, communications, and/or tangible objec

fices of "Main Justice," the Federal Bureau of Investigation and all United States Attorney's Offices), the Securities and Exchange Commission, and the Department of Homeland Security. In addition, such information includes infonnation in the possession, custody, and control of any local, state, or I All of these requests are/wil

en the Department of Justice and Mr. Epstein (the "NPA"). Each is subject to disclosure pursuant to the government's obligations under, inter alia, Brady v. Maryland, 373 U.S. 83 (1963) and the Federal Rules of Criminal Procedure. Mr. Epstein seeks all documents, communications, and/or tangible objec

fices of "Main Justice," the Federal Bureau of Investigation and all United States Attorney's Offices), the Securities and Exchange Commission, and the Department of Homeland Security. In addition, such information includes information in the possession, custody, and control of any local, state, or I All of these requests are/wil

en the Department of Justice and Mr. Epstein (the "NPA"). Each is subject to disclosure pursuant to the government's obligations under, inter alia. Brady v. Maryland, 373 U.S. 83 (1963) and the Federal Rules of Criminal Procedure. Mr. Epstein seeks all documents, communications, and/or tangible objec

fices of "Main Justice," the Federal Bureau of Investigation and all United States Attorney's Offices), the Securities and Exchange Commission, and the Department of Homeland Security. In addition, such information includes infonnation in the possession, custody, and control of any local, state, or I All of these requests are/wil

7, 1941, was "a date which will live in infamy," Kelly declared: "Today, December the 18th, 2019, is another date that will live in infamy." Rep. Brady (R-Tex) said Democrats will be remembered as the "Senator Joe McCarthys of our time" for trying "to plunge America into darkness for raw political

— measures that would make it harder for many to seek refuge in the U.S. Nick Miroff reports: "The proposed change from the Justice Department and the Department of Homeland Security would disqualify asylum applicants found guilty of serious offenses such as driving while into'dcated and domestic battery, as well as lesser viola

7, 1941, was "a date which will live in infamy," Kelly declared: "Today, December the 18th, 2019, is another date that will live in infamy." Rep. Brady (R-Tex.) said Democrats will be remembered as the "Senator Joe McCarthys of our time" for trying "to plunge America into darkness for raw political

- measures that would make it harder for many to seek refuge in the U.S. Nick Miroff reports: "The proposed change from the Justice Department and the Department of Homeland Security would disqualify asylum applicants found guilty of serious offenses such as driving while intoxicated and domestic battery, as well as lesser viola

mited to the Federal Bureau of Investigation ("FBI") and all United States Attorney's Offices), the Securities and Exchange Commission ("SEC"), and the Department of Homeland Security. In addition, such information includes information in EFTA00016136 --- PAGE BREAK --- August 1, 2019 Page 2 Steptoe Lorna! ailOHNSON LLP the

entify the "other" overt acts ("the following overt acts, among others") referenced in ¶ 22 of the indictment. IV. Brady Material A. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976)