3
Shared Docs
3
Same-Page
3 / 3
Mentions
t's alternatives are most relevant to this case. A specific employment practice or policy can comprise affirmative acts or inaction. Cf. Ellison v. Brady, 924 F.2d 872, 881 (9th Cir. 1991) (explaining an employer's responsibility to act to rectify a hostile or offensive work environment under Title VI
m the date of the employment decision[s], or if they were not related to the employment decision[s] in question or were made by nondecisionmakers." McMillan v. Mass. Soc'y for Prevention of Cruelty to Animals, 140 F.3d 288, 301 (1st Cir. 1998). Here, Plaintiffs' evidence suffers to ("153] some degree fr
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
stigation IS 9/10/07- 9/19/07 Entails between Alex Acosta, Jeff Montan, Andrew Laurie, Rolando Garcia, Karen Atkinson, Marie Villafafia, andJohn McMillan regarding plea negotiations 47 9/10/07- 9/11/07 Entails from Marie Viktoria to Gerakl I cfcourt with proposed Non-Prosecution Apvements PI 9/1
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
een Mr. Lefkowitz and myself that any appeal to Washington would be undertaken expeditiously. On September 7, 2007,1, along withFAUSA Sloman, AUSAs McMillan and Villafafta, and FBI agents, met with you, Mr. Lefkowitz, and Ms. Sanchez. I understood that you wished to present federalism-based concerns reg
Entities connected to both Brady and McMillan

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONLeon Black
PERSONFBI
ORGANIZATION
Donald Trump
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSON
Bradley Edwards
PERSON
A. Marie Villafana
PERSON
Julie K. Brown
PERSONCollins
PERSON
Supreme Court
ORGANIZATION
Bill Clinton
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON