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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
EFING SCHEDULE AND HEARING ON THE APPROPRIATE REMEDIES. For all the reasons just explained, the Court should find that the Government has violated Jane Doe NI and Janc Doe #2's rights under the CVRA. At the tail end of its brief, however, the Government briefly raises a flurry of desperate arguments to avo
r statements, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail
tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres
r statements, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail
tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres
Entities connected to both Brady and Jane Doe NI

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
George W. Bush
PERSONFBI
ORGANIZATION
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJane Doe
PERSON
Paul Cassell
PERSONLeon Black
PERSON
Southern District of New York
ORGANIZATION
Kenneth Marra
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSON
A. Marie Villafana
PERSON
Barry Diller
PERSON