Epstein Secrets

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

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). EFTA00179738 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 41 of 64 On September 26, 2011, the Court den

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Co

it has identified. Because the information provided by these women goes directly to the question of Mr. Epstein's guilt or innocence, it is classic Brady information. We understand that the U.S. Attorney might not want to disclose impeachment information about their witnesses prior to a charge or dur

the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While there, he routinely conducted business, received medical atte

it has identified. Because the information provided by these women goes directly to the question of Mr. Epstein's guilt or innocence, it is classic Brady information. We understand that the U.S. Attorney might not want to disclose impeachment information about their witnesses prior to a charge or dur

the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While there, he routinely conducted business, received medical atte

withhold relevant information contrary to its position in court. In their motion (at pp. 5-9), the victims explained why fairness entitles them to "Brady" information (i.e., information contradicting the Government's position) no less than criminal defendants. In response, the Government does not eve

o reply to the Government's Response (DE #58) to their Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE #49). The victims' proffered facts should all be accepted by the Court. The Government claims that it can prevail regardless of what the true f

Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (S.D.N.Y. Sept. 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Maxwel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.

0077571 Table of Contents Table of Contents Table of Authorities ii Table of Exhibits iv Introduction and Summary of the Argument 1 I. The Facts 2 II. The Government's Response to Maxwell's Motion. 6 A. The Government's Defenses Are Not Credible. 7 B. Assuming the Government's Defense