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statements, their credibility and the foundations. il' any. for claiming personal istiory. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the Ponta of prior inconsistent statements made by these women before they learned of any financial benefit that may be avai
l of cuir concerns on this matter. I respectfully request that you consider the issues I discuss below in conjunction with the ethics opinion of Mr. Joe D. Whitley that I faxed to your Office on December 7. liackifroond of Negotiations I believe it is inmortant fur you to he aware of the full scope and substa
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
nce and the federal interest in the case. At this point, Epstein sought review from Deputy Attorney General Mark Filip (Exhibit B- 33), and he hired Joe Whitley to join his defense team. I was informed that Epstein's deadline to enter his guilty plea would be extended again, and we continued preparinii indic
each was astonished that any evidence Ms. Villafana purported to have was not shared with the State or made available to Mr Epstein's attorneys as Brady evidence. Ms. Villafana launched a totally unsupportable and vastly overreaching sex trafficking investigation without providing notification to th
er, Nat Dershowitz, Ken Starr, Jay Lefkowitz, Lilly Sanchez, Jack Goldberger, Bruce Lyons, Martin Weinberg, Stephanie Thacker, Guy Lewis, Mike Tein, Joe Whitley and Herb Rosen, have expressed sincere outrage over this wholly unwarranted and duplicative 18-month federal investigation of purely local conduct
reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L.Ed.2d 215 (1963), prosecutors must disclose all evidence, upon request, that is favorable to the def
P.C., New York, NY (4) Lilly Ann Sanchez, Fowler White Burnett, Miami, FL; (5) Jack A. Goldberger, Goldberger & Weiss, West Palm Beach, FL; and (6) Joe D. Whitley, Alston & Bird, Washington D.C.; as well as Harvard Law Professor Alan Dershowitz. While not all attorneys participated in each defense presentation
statements. their, credibility and the foundations. if any. fir claiming personal injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in tlx: form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avai
rable Mark Filip Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N. w. Washington, D.C. 20530 Joe D. Whitley Alston & Bird LIP the Atlantic Building 950 I' Street, NW washinglun, DC aoun4-1404 Ph: 202.756-3189 Fax: 202.654.4889 joe.whitlengialston.cum
ir statements, their credibility and the foundations, if any, for claiming person! injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the tbnn of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail
not considered by CEOS which were recently raised in correspondence by two former high-ranking members of the Department of Justice - Ken Stan and Joe Whitley. On May 28,2008, I notified Mr. Lefkowitz by e-mail that the SDFL has postponed the June 2, 2008 deadline until the DAG's Office has completed its r
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
Letter stating the defense will respond to Acosta letter by 12/10/07, and attaching " the independent ethics opinions of Judge Herbert J. Stern and Joe D. Whitley" 12/7/2007 Alan Dershwitz Herbert J. Stem Letter - 27 pages 12/7/2007 Kenneth Starr R. Alexander Acosta Independent ethics opinions of Judge H
Entities connected to both Brady and Joe D. Whitley

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Prince Andrew
PERSON
Alexander Acosta
PERSONLeon Black
PERSONFBI
ORGANIZATION
Joe Biden
PERSON
Ken Starr
PERSON
Jay Lefkowitz
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSONMartin Weinberg
PERSONJane Doe
PERSON
Bill Clinton
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON