Epstein Secrets

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

the transmittal of information (in the form of facts, ideas, inquiries or otherwise). EFTA00100776 Offices for the Southern District of Florida, the Middle District of Florida, and/or the Northern District of Georgia (or FBI agents working therewith); 2. Any investigatory files that were received or accessed by

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

o the Epstein matter, as well as any information that developed about that conflict after the Epstein matter was referred to another district (e.g., the Middle District of Florida). See Victims' First RFP's at ¶ 18; Victims' Second FRP's at ¶ 1. The victims know that the USAO-SDFL was in fact conflicted out of som

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

the transmittal of information (in the form of facts, ideas, inquiries or otherwise). EFTA00073645 Offices for the Southern District of Florida, the Middle District of Florida, and/or the Northern District of Georgia (or FBI agents working therewith); 2. Any investigatory files that were received or accessed by

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

the transmittal of information (in the form of facts, ideas, inquiries or otherwise). EFTA00085285 Offices for the Southern District of Florida, the Middle District of Florida, and/or the Northern District of Georgia (or FBI agents working therewith); 2. Any investigatory files that were received or accessed by

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

ive entity, and any grand jury investigating these (or releated) allegations, including any grand jury meeting in the Southern District of Florida, the Middle District of Florida, the District of EFTA00179741 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 44 of 64 New Jersey, and/o

e these cases all over the country, and he had never had to file a complaint. Now he claims the Federal Rules of Civil Procedure, to say nothing of Brady and Giglio, also apply. From: Sent: Sunda To: Cc: (USAFLS) March 20, 2011 2:40 PM USAFLS (USAFLS); (USAFLS) Subject: Planned response to to

Cassell has, however, been successful in the 11th, in In re Stewart, 552 F.3d 1285 (11th Cir. 2008), where Cassell filed a writ of mandamus to have the Middle District of Florida recognize home purchasers as victims in a guilty plea to an Information by a bank executive. The executive was pleading guilty to money l

e these cases all over the country, and he had never had to file a complaint. Now he claims the Federal Rules of Civil Procedure, to say nothing of Brady and Giglio, also apply. From: Sent: Sunda To: Cc: (USAFLS) March 20, 2011 2:40 PM USAFLS (USAFLS); (USAFLS) Subject: Planned response to to

Cassell has, however, been successful in the 11th, in In re Stewart, 552 F.3d 1285 (11th Cir. 2008), where Cassell filed a writ of mandamus to have the Middle District of Florida recognize home purchasers as victims in a guilty plea to an Information by a bank executive. The executive was pleading guilty to money l