Epstein Secrets

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

l law violations. After a spate of stories about the case last week?, New York publicist Dan Klores - whose client list has included Paris Hilton and Jennifer Lopez - said on Saturday that Epstein’s camp was ready “to get their story out.” They did that Monday via Goldberger and a Los Angeles publicist for Miami

lient list has included Paris Hilton and Jennifer Lopez - said on Saturday that Epstein’s camp was ready

d Order a Bill of Particulars as to Counts Five and Six. 22 VII. The Court Should Order the Government to Produce Accuser-4's Prior Statements as Brady Material 24 VIII. Ms. Maxwell Incorporates All of the Arguments Raised in Her Initial Pretrial Motions and Reasserts Them as to the S2 Indictment

nited States v. Harvey, 791 F.2d 294 (4th Cir. 1986) 15 United States v. Korfant, 771 F.2d 660 (2d Cir.1985) 19 EFTA00103760 United States v. Lopez, 356 F.3d 463 (2d Cir. 2004) 18, 19, 20 United States v. Rooney, 37 F.3d 847 (2d Cir. 1994) 17, 18 United States v. Salameh, 152 F.3d 88 (2d C

Jeopardy Clause's Protection Against Duplicative Punishments. 11 III. The Government Should Immediately Produce Accuser-4's Prior Statements as Brady Material. 14 IV. The Court Should Grant Ms. Maxwell's Other Requested Relief. 16 CONCLUSION 17 i EFTA00104412 TABLE OF AUTHORITIES Page

04) 7 United States v. Korfant, 771 F.2d 660 (2d Cir.1985) 9 United States v. Laskow, 688 F. Supp. 851 (E.D.N.Y. 1988) 8, 10 United States v. Lopez, 356 F.3d 463 (2d Cir. 2004) 9, 11 United States v. Prisco, 391 F. App'x 920 (2d Cir. 2010) 7 United States v. Rivera, 844 F.2d 916 (2d Cir. 1

t's alternatives are most relevant to this case. A specific employment practice or policy can comprise affirmative acts or inaction. Cf. Ellison v. Brady, 924 F.2d 872, 881 (9th Cir. 1991) (explaining an employer's responsibility to act to rectify a hostile or offensive work environment under Title VI

3d at 1201 (7.95 and 38.03 standard deviations); Lopez v. Laborers Intl Union Local No. 18, 987 F. 2d 1

4. 918. "A Bacterial Printing Press that Regenerates its Ink: Contact Printing Bacteria Using Hydrogel Stamps", Weibel, D. B., Lee, A., Mayer, M., Brady, S. F., Bruzewicz, D. A., Yang, 1, DiLuzio, W., Clardy, J. and Whitesides, G. M., Langmuir, 2005, 21, 6436-6442. 917. 916. "Water-Soluble Sacrifi

, A., Wood-Kingery, J. E. and Whitesides, G. M., J. Med. Chem., 1994, 37, 3419-3433. "Engineering Cell Shape and Function", Singhvi, R., Kumar, A., Lopez, G. P., Stephanopolous, G. N., Wang, D. I. C., Whitesides, G. M. and Ingber, D. E., Science, 1994, 264, 696-698. "Reagents for Rapid Reduction of N

7, 1941, was "a date which will live in infamy," Kelly declared: "Today, December the 18th, 2019, is another date that will live in infamy." Rep. Brady (R-Tex) said Democrats will be remembered as the "Senator Joe McCarthys of our time" for trying "to plunge America into darkness for raw political

bani Mahtani) 7. Mexican President Andres Manuel Lopez Obrador's cost- cutting spree is generating chaos

lso United States v. Ruiz, 536 U.S. 622, 629 (2002) (quoting Weatherford, 429 U.S. at 559). 298 Wardius v. Oregon, 412 U.S. 470,474 (1973). 299 See Brady v. Maryland, 373 U.S. 83, 87 (1963). 300 See United States v. Bagley, 473 U.S. 667, 675 (1985). 301 United States v. Garrett, 238 F.3d 293, 302 (St

351 (1959)). 3 o ° United States v. Bobadilla-Lopez, 954 F.2d 519, 521 (9th Cir. 1992). 3 o ! Unit

, Northfield, IL, for Blaise Messino. Joseph R. Lopez, Chicago, IL, for Paul Messino. Walter Jones, Jr

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

charges are sufficiently specific. • Maxwell moves to compel the Government to produce the statements of "Minor-Victim 4" in the S2 indictment as Brady material. The Court concludes that the current disclosure schedule gives Maxwell sufficient time to make effective use of any such statements and t

rosecutions of a particular defendant for the same conspiracy, not separate prosecutions of individual co-conspirators. See, e.g., United States v. Lopez, 356 F.3d 463, 469 (2d Cir. 2004). The Double Jeopardy Clause does not require all co- conspirators be tried together for related offenses. See Zafir