Epstein Secrets

ntifying these witnesses and their prior statements are exculpatory evidence, which must be disclosed pursuant to the government's obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny.' Second, the Court should order the government to disclose the Materials under Rule 16 because th

when the government has made a sufficient showing that disclosure may lead to witness intimidation or threats to their safety. See United States v. Urena, 989 F. Supp. 2d 253, 262-63 (S.D.N.Y. 2013) (collecting cases). The government has done neither here. The government has not made any showing that

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

pretrial disclosure of the disputed evidence would enable the defendant significantly to alter the quantum of proof in his favor." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (internal quotation marks, citation, and alterations omitted). Evidence is "within the [G]ovemment's poss

ntifying these witnesses and their prior statements are exculpatory evidence, which must be disclosed pursuant to the government's obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny.' Second, the Court should order the government to disclose the Materials under Rule 16 because th

when the government has made a sufficient showing that disclosure may lead to witness intimidation or threats to their safety. See United States v. Urena, 989 F. Supp. 2d 253, 262-63 (S.D.N.Y. 2013) (collecting cases). The government has done neither here. The government has not made any showing that