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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.15 Since witness credibility was clearly at the fore, I undertook efforts 14 The requested documents and items were never provided. 15 As th
ed I letter from attorney Richard Willits, advising me that he represented Individual #3 and that he had filed suit on her behalf against Epstein in Palm Beach County Circuit Court (Exhibit B-41). I responded, acknowledging his representation (Exhibit B-42). On June 18, 2008, I received I call from attorney Brad Edwards, who t
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
position, immaterial to the present litigation, on whether Jeffrey Epstein ("Epstein") committed crimes (other than those to which he pled guilty in Palm Beach County Circuit Court). 'For example, Petitioners were repeatedly advised the Epstein lived in Palm Beach, not West Palm Beach. Even this simple correction was ignored.
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
position, immaterial to the present litigation, on whether Jeffrey Epstein ('Epstein") committed crimes (other than those to which he pled guilty in Palm Beach County Circuit Court). 'For example, Petitioners were repeatedly advised the Epstein lived in Palm Beach, not West Palm Beach. Even this simple correction was ignored.
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
position, immaterial to the present litigation, on whether Jeffrey Epstein ('Epstein") committed crimes (other than those to which he pled guilty in Palm Beach County Circuit Court). 'For example, Petitioners were repeatedly advised the Epstein lived in Palm Beach, not West Palm Beach. Even this simple correction was ignored.
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
tter - 5 pages (CEOS) B-28 3/28/2008 Villafalia Danchuk Letter advising of representation of Individual #3 and that a lawsuit has been filed in Palm Beach County Circuit Court B-41 4/1/2008 Jay Lefkowitz Jeffrey Sloman Draft letter regarding termination of agreement Privileged Confidential Page 32 of 51 Contains 6(c)
CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very I familiar with it. It is analogous. It is a situation where there was trem
th Epstein, Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein’s agreement to settle lawsuits filed a
Entities connected to both Brady and Palm Beach County Circuit Court

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Giglio
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
George W. Bush
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSONLeon Black
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Southern District of New York
ORGANIZATION
Alan Dershowitz
PERSON
Supreme Court
ORGANIZATIONMartin Weinberg
PERSON