Epstein Secrets

ssurances of preservation -- requires a full factual record and, if appropriate, sanctions for the loss of the evidence. The Supreme Court held in Brady v. Maryland, 373 U.S. 83, 87 (1963), that "the suppression by the prosecution of evidence favorable to the accused upon request violates due proces

bly available means," California v. Trombetta, 467 U.S. 479, 489 (1984), and must also show that the government acted in bad faith. United States v. Greenburg, 835 F.3d 295, 303 (2d Cir. 2016); United States v. Rastelli, 870 F.2d 822, 833 (2d Cir. 1989). In other words, when the Government fails to preser

s regarding Epstein not wanting underage girls providing him massages would have been required to be disclosed to Epstein's defense attorneys under Brady v. Maryland 373 U.S. 83 (1963). If the government ever chose to call her as a prosecution witness, the government would have been obligated to discl

er 10, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY 29 EFTA00800036

s regarding Epstein not wanting underage girls providing him massages would have been required to be disclosed to Epstein's defense attorneys under Brady v. Maryland 373 U.S. 83 (1963). If the government ever chose to call her as a prosecution witness, the government would have been obligated to discl

ber 6, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY 29 EFTA00800004

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

neys, and First Assistant U.S. Attorney Benjamin Greenberg, "regarding Formal Notice of Office-wide Recusal

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

Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern Distric

CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very I familiar with it. It is analogous. It is a situation where there was trem

PEARANCES: On behalf of the Plaintiff/Petitioner: GREENBERG TRAURIG, P.A. 1840 Century 'Park East Suite 1900

Chicago, IL, for Daniel C. Shoemaker. Steven A. Greenberg, Chicago, IL, Richard Friedman, WESTLAW © 2019 T

d. VIII. DEFENDANT CHRISTOPHER RICHARD MESSINO'S MOTION FOR PRODUCTION OF EXCULPATORY OR IMPEACHING MATERIAL Defendant seeks material pursuant to Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), and Giglio v. United States, 405 U.S. 150, 92 S.Ct. 763, 31 L.Ed.2d 104 (1972). Sp