Epstein Secrets

16 of the Federal Rules of Criminal Procedure, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires t

the night of August 9, 2019 and the morning of August 10, 2019, certifying that he conducted counts of the inmates he was supervising in the MCC's Special Housing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Eps

16 of the Federal Rules of Criminal Procedure, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires t

the night of August 9, 2019 and the morning of August 10, 2019, certifying that he conducted counts of the inmates he was supervising in the MCC's Special Housing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Eps

16 of the Federal Rules of Criminal Procedure, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires t

the night of August 9, 2019 and the morning of August 10, 2019, certifying that he conducted counts of the inmates he was supervising in the MCC's Special Housing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Eps

for their U.S. fleets in coming years, undercutting one of the Trump administration's most aggressive climate policy rollbacks. Juliet Eilperin and Brady Dennis report: "The compromise between the California Air Resources Board and Ford, Honda, Volkswagen and BMW of North America came after weeks of

and Thomas sat at their desk, browsed the Internet, and moved around the common area' of the section of the jail where Epstein was held, known as the Special Housing Unit, or SHU, the grand jury charged. The indictment charges that Noel and Thomas repeatedly signed false 'count slips' even though they failed to condu

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

Race: WHITE Facility: NYM Encounter Date: 08/10/2019 07:25 Provider: RN Unit: Z04 Emergency Code - Resuscitation Event encounter performed at Special Housing Unit. SUBJECTIVE: Emergency Note Provider: RN Team Members: Provider fiQle RN Team/Code Leader Code Events: Tvoe Value Pate CPR Compressions

u believe someone may have posted information relevant to this case. 2 The Government is producing video surveillance footage of the common area of the Special Housing Unit for the above-referenced dates. On or about August 10, 2019, the Government seized 06.20.2018 EFTA00027732 --- PAGE BREAK --- Page 2 Commissary

d Materials Anonymized Index (Produced Under Separate Cover) SDNY_00008123 Attorney's Eyes' Only The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government wishes to bring your attention to the following statements, which could constitute

produce these materials if and when the Court orders their production. Beyond the above materials, to date, the Government is unaware of any other Brady material regarding your client, but will provide timely disclosure if any such material comes to light. The Government will provide material under G

u believe someone may have posted information relevant to this case. 2 The Government is producing video surveillance footage of the common area of the Special Housing Unit for the above-referenced dates. On or about August 10, 2019, the Government seized 06.20.2018 EFTA00025239 --- PAGE BREAK --- Page 2 Commissary

d Materials Anonymized Index (Produced Under Separate Cover) SDNY_00008123 Attorney's Eyes' Only The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government wishes to bring your attention to the following statements, which could constitute

ssurances of preservation -- requires a full factual record and, if appropriate, sanctions for the loss of the evidence. The Supreme Court held in Brady v. Maryland, 373 U.S. 83, 87 (1963), that "the suppression by the prosecution of evidence favorable to the accused upon request violates due proces

the requested video) no longer exists" (1/9/20 Letter: 1). Further, the Government explained, "the backup system in place that housed all video for the Special Housing Unit, including the video requested by defense counsel . . . no longer exists . . . and has not since at least August 2019 as a result of technical erro

the night of August 9, 2019 and the morning of August 10, 2019, certifying that he conducted counts of the inmates he was supervising in the MCC's Special Housing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Eps

16 of the Federal Rules of Criminal Procedure, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires t