Epstein Secrets

ed to provide the draft indictment. We understand that we have no statutory right to a FBI 302 that inculpates Mr. Epstein (although we believe that Brady principles would encourage the disclosure of FBI 302 reports that exonerate him). We are concerned that there is information that could be rebutted

olicy issues raised by your Office's invocation of § 2255. It is common ground among us that § 2255 has not been the subject of policy guidance from Main Justice, over the long life of this unusual statute. It is therefore undisputed that we are sailing in uncharted jurisprudential and policy waters. This sh

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

er requests contained herein) ask you communicate our preservation request to AUSAs of the Northern District of Georgia, to CEOS and anyone e se at Main Justice that you have knowledge of as being involved in communications regarding the NPA and the decision by the Southern District of New York to indict, an

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

uests contained herein) ask you communicate our preservation request to AUSAs and of the Northern District of Georgia, to CEOS and anyone else at Main Justice that you have knowledge of as being involved in communications regarding the NPA and the decision by the Southern District of New York to indict, an

ed to provide the draft indictment. We understand that ac have no statutory right to a FBI 302 that inculpates Mr. Epstein (although we believe that Brady principles would encourage the disclosure of FBI 302 reports that exonerate him). We are concerned that there is information that could be rebutted

y issues raised by your Office's invocation of § 2255. It is co m mon ground among us that Si 2255 has not been the subject or policy guidance front Main Justice. over the long life of this unusual statute. It is therefore undisputed that we are sailing in uncharted jurisprudential and policy waters. This sh

e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady v. Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the Office to extend to the victims the same assistance that it would

ntial conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that EFTA00179731 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 3