Epstein Secrets

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

luding gross misstatements of witness statements and other evidence. Second, we (Continued...) 2 08-80736-CV-MARRA RFP WPB 001655 EFTA00209834 KIRKLAND 8. ELLIS LLP Mr. Epstein is Required to Agree to Civil Liability In Order to Avoid a Federal Indictment 10. On 31, 2007, during ne otiations over a

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

de a DNA sample in court at the time of ' V . • !iiah Assitetaittlaie Adorn,* • /c://. O f Defendant EFTA00234617 Exhibit 13 EFTA00234618 KIRKLAND 8. ELLIS LLP AND At TILIATED PAIONIASMItS Jay P. Leatowitt, P.C. To . .com VIA E-MAIL Citigroup Center 163 East 53rd Street New York, New York

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

de a DNA sample in court at the time of ' V . • !iiah Assitetaittlaie Adorn,* • /c://. O f Defendant EFTA00213095 Exhibit 13 EFTA00213096 KIRKLAND 8. ELLIS LLP AND At TILIATED PAIONIASMItS Jay P. lielcowitt, P.C. To . Cingroup Center 163 East SW Street New York, New York 10022-4811 www.kir