Epstein Secrets

NY 10022 ♦1 212 957 7600 phono www colsmipossoo corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request

rors, witnesses under examination, court reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the g

evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agurs, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We request all such evidence requested above and e

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)

ial 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), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practic

ision series of the New York Times, concerning the same. In your letter, you cite Federal Rule of Evidence 16(a)(1)(E)(i), the Due Process Clause, Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), and their progeny. However, insofar as your request is premised on th

cution team (which is not on any Jeffrey Epstein-related investigation) both had it and was at liberty to provide it. See generally United States v. Agurs, 427 U.S. 97, 109 n.16 (1976). We also note that Scott Wilson, Esq. has moved from BSF to DLA Piper. Notwithstanding this view, we are available to

the victims and permit inspection and copying of all information and material known to the government which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possibl

t which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment inf

e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady'. 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

may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United States. Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States, Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin

the victims and permit inspection and copying of all information and material known to the government which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possibl

t which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment inf

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

may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United States. Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States, Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin

e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady' 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 p

may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United Stales, Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States' Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin