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Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (S.D.N.Y. Sept. 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Maxwel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.
ication of the civil Protective Order entered by Judge Sweet—AUSA shared with AUSA as well as one other member of the trial team and the heads of the Public Corruption Unit, everything she learned from her contacts with =attorneys. Ex. N. AUSA gave AUSA and his colleagues: (1) nine pages of detailed, hand-written n
ed or disclosed through this FOIA action. 13. Greater Access: Pursuant to its obligations under Federal Rule of Criminal Procedure 16, as well as Brady v. Maryland, 373 U.S. 83 (1963), and directives from the District Court, the Government has provided Maxwell's counsel with discoverable and potent
s Deputy Chief of the Violent and Organized Crime Unit of the USAO-SDNY from February 2021 through May 2021, an Assistant United States Attorney in the Public Corruption Unit of the USAO-SDNY from September 2019 through February 2021, an Assistant United States Attorney in the Violent and Organized Crime Unit of the USAO
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
such as Epstein's high-powered friends, would be charged. He brushed off questions about the significance that the investigation was being handled by the Public Corruption Unit. While agents on Saturday were -arresting Epstein aboard his private jet .at the Teterboro Airport in NewJersey after returning from Paris, Other off
ication of the civil Protective Order entered by Judge Sweet—AUSA shared with AUSA as well as one other member of the trial team and the heads of the Public Corruption Unit, everything she learned from her contacts with attorneys. Ex. N. AUSA gave AUSA and his colleagues: (1) nine pages of detailed, hand-written no
Page: EFTA00028938 →l filed her Motion, she did not have access to the government's emails and AUSA contemporaneous notes, despite their obvious exculpatory value. See Brady v. Maryland, 373 U.S. 83, 87-88 (1963). The government did not disclose these materials until Maxwell challenged the government's candor and conduc
Page: EFTA00028944 →ses Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (.=. Sept 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Marcel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 19
Page: EFTA00029102 →ication of the civil Protective Order entered by Judge Sweet—AUSA shared with AUSA as well as one other member of the trial team and the heads of the Public Corruption Unit, everything she learned from her contacts with attorneys. Ex. 1 . AUSA gave AUSA and his colleagues: (1) nine pages of detailed, hand-written
Page: EFTA00029109 →Entities connected to both Brady and the Public Corruption Unit

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Bradley Edwards
PERSON
George W. Bush
PERSON
Donald Trump
PERSONLeon Black
PERSON
Paul Cassell
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
Southern District of New York
ORGANIZATION
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Supreme Court
ORGANIZATION
Bill Clinton
PERSON
Alexander Acosta
PERSON