Epstein Secrets

it includes information regarding records designated as "confidential" under the Protective Order. The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and

_00007658; SDNY_GM_00007666; SDNY_GM_00007676; SDNY_GM_00007677 T-Mobile records Confidential SDNY GM 00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors) Confidential SDNY_GM_00008137 SDNY_GM_00008137 UMB Bank no records notification Confidential SDNY_

00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors) Con

SDNY GM 00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executo

it includes information regarding records designated as "confidential" under the Protective Order. The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and

_00007658; SDNY_GM_00007666; SDNY_GM_00007676; SDNY GM_00007677 T-Mobile records Confidential SDNY_GM_00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors) Confidential SDNY_GM_00008137 SDNY_GM_00008137 UMB Bank no records notification Confidential SDNY_

00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors) Con

SDNY_GM_00007678 SDNY_GM_00008136 Materials from Darren Indyke and Richard Kahn (Epstein Estate Executo

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

tax year beginning (month day. year) / o # I 01 E Name and title of officer or legal representative who the IRS may call for more Information Darren K. Indyte, Vice Presidnt F Telephone number of officer or legal representative H II the corporation changed its name or address after applying RN the EIN s

tative who the IRS may call for more Information Darren K. Indyte, Vice Presidnt F Telephone number of off

tative who the IRS may call for more Information Darren K. Indyte, Vice Presidnt F Telephone number of offi

s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t

per week and earned no compensation. (Sag page 6 of each return.) All of these returns were signed under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor." Mr. Epstein's representations concerning his prior work duties and

lary and employment verification requirements of C.O.P. #926.01(V)(CX7) and (8). In response to your requirement of "a detailed work schedule," Mr. Indyke has provided the following two sentences: [Mr. Epstein's] duties will require him to work six days a week, Monday through Saturday, at the Foundat

under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work rele

s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t

per week and earned no compensation. (See page 6 of each return.) All of these returns were signed under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor." Mr. Epstein's representations concerning his prior work duties and

lary and employment verification requirements of C.O.P. #926.01(V)(CX7) and (8). In response to your requirement of "a detailed work schedule," Mr. Indyke has provided the following two sentences: [Mr. Epstein's] duties will require him to work six days a week, Monday through Saturday, at the Foundat

under penalty of perjury by either Mr. Epstein or Darren Indyke, who is listed in Mr. Epstein's work rele

ompensation payments and application for and receipt of emergency victim compensation payments may well have been 'favorable' within the meaning of Brady," requiring government disclosure of exculpatory evidence to criminal defendants); payments and promises made to cooperating witnesses. See also, Un

rogram and Renewed Request for Ruling, Fanner v. Indyke, No. 19-cv-10475-LGS-DCF, Dkt. 73-1. 1. Specific

ompensation payments and application for and receipt of emergency victim compensation payments may well have been 'favorable' within the meaning of Brady," requiring government disclosure of exculpatory evidence to criminal defendants); payments and promises made to cooperating witnesses. See also, Un

sation Program and Renewed Request for Rulinay. Indyke, No. 19-cv-10475-LGS-DCF, Dkt. 73-1. 1. Specific