Epstein Secrets

ffice." Letter from Bradley J. Edwards & Paul G. Cassell to Wifredo A. Ferrer, Mar. 1, 2011. The victims h

aterial to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office." Letter from Bradley J. Edwards & Paul G. Cassell to Wifredo A. Ferrer, Mar. 1, 2011. The victims have, for example, requested that the U.S. Attorney's Office provide to them unredacted copies of co

may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United States. Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States, Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin

"civil" case. 6 EFTA00177110 Case 9:08-cv-80736-KAM Document 49 Entered on FLSD Docket 03/21/2011 Page 7 of 10 Letter from Wifredo A. Ferrer to Paul G. Cassell (March 15, 2011).3 Accordingly, the victims were left with no choice but to file a motion without stipulated facts. Contemporaneously with the filin

f the proposed "undisputed material facts" arc in fact disputed and, in many cases, wrong. 'The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct

may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United Stales, Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States' Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin

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

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 request all such evidence requested above and e