Epstein Secrets

th.net Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg [email protected] Via Facsimile and R

e Warthen Ezell [email protected] Paul G. Cassell [email protected] Richard Horace Willit

is material to the guilt of Alfredo Rodriguez, regardless of whether that information was requested by the Defendant or not. See United States v. Bagley, 473 U.S. 667 (1985). See also Fed.R.Crim P. 16(a)(1)(E). Evidence is material that creates a reasonable probability that the outcome of a crimina

attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14. We request all written and oral

McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r

attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14. We request all written and oral

McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r

attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14. We request all written and oral

McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r

attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14. We request all written and oral

McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r

McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys

attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14. We request all written and oral

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r

attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14. We request all written and oral

McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r

ictims Fairly: Integrating Victims into the Federal Rules o Criminal Procedure 2007 Reporter 2007 Utah L. Rev. 861 * Length: 59852 words Author: Paul G. Cassell* * Professor of Law, S.J. Quinney College of Law of the University of Utah, Judge, U.S. District Court for the District of Utah, 2002-07. Thanks to

in the Federal Rules of Criminal Procedure: Proposed Amendments in Light of the Crime Victims’ Rights Act, 2005 BYU L. Rev. 835, 852-924 [hereinafter Cassell, Proposed Amendments]. 5 18 U.S.C. § 3771 (a)(8). DAVID SCHOEN HOUSE_OVERSIGHT_017637 --- PAGE BREAK --- Page 3 of 78 2007 Utah L. Rev. 861, *865

ord, 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 (Sth Cir. 2000) (citation and internal quotation marks omitted). 302, Ba

rnment and the attorneys for these individuals — including , but not limited to, , David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14. We request all written and oral communicati

McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and (the "Attorneys") — concern

t. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agurs, 427 U.S. 97 (1976). We also make the following specific Brady requests: I. Exculpatory Evidence: We r