Epstein Secrets

presumed that Congress acts intentionally and purposely in the disparate inclusion or exclusion." Duncan v. Walker 533 U.S. 167, 173 (2001), citing Bates v. United States 522 U.S. 23, 29-30 (1997). Petitioners contend the government was required under § 3771(a)(5) to notify them of the negotiation o

l her as a prosecution witness, the government would have been obligated to disclose her prior exculpatory statements as impeachment material under Giglio v. United States, 405 U.S. 150 (1972). While petitioners attempt to rehabilitate Jane Doe 2 by relying upon theories of victimization, to explain h

presumed that Congress acts intentionally and purposely in the disparate inclusion or exclusion." Duncan v. Walker 533 U.S. 167, 173 (2001), citing Bates v. United States 522 U.S. 23, 29-30 (1997). Petitioners contend the government was required under § 3771(a)(5) to notify them of the negotiation o

l her as a prosecution witness, the government would have been obligated to disclose her prior exculpatory statements as impeachment material under Giglio v. United States, 405 U.S. 150 (1972). While petitioners attempt to rehabilitate Jane Doe 2 by relying upon theories of victimization, to explain h

id the defense in its trial preparation and review of the discovery, EFTA00080584 Page 4 today the Government provided the defense with a list of Bates ranges within the discovery materials produced to date that are particularly relevant to Minor Victim-4. Although that list is not exhaustive and d

tly as possible in advance of trial. Finally, given the expanded charges in the S2 Indictment, the Government is prepared to produce Jencks Act and Giglio material for witnesses it expects to call at trial six weeks, rather than four weeks, in advance of trial. These productions, together with the guid

ve attached copies of the documents listed below if they were not provided to the defense by the government in discovery. Otherwise, we provide the Bates numbers for the produced documents. Because we have already provided the government with the defense expert notice, which referenced articles, repor

ent requests which the defense may want to use in any case-in-chief. Third, the government is still producing Rule 16 discovery, 3500 material, and Giglio material, which may require additional investigation and may, in turn, yield additional documents that the defense may wish to use in any case-in-ch

id the defense in its trial preparation and review of the discovery, EFTA00099168 Page 4 today the Government provided the defense with a list of Bates ranges within the discovery materials produced to date that are particularly relevant to Minor Victim-4. Although that list is not exhaustive and d

tly as possible in advance of trial. Finally, given the expanded charges in the S2 Indictment, the Government is prepared to produce Jencks Act and Giglio material for witnesses it expects to call at trial six weeks, rather than four weeks, in advance of trial. These productions, together with the guid

0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy

ulted by Mr. Epstein, with or without the involvement of Ms. Maxwell, had a financial motive or incentive to accuse Mr. Epstein or Ms. Maxwell. 6. Giglio Information: Pursuant to Giglio v. United States, 405 U.S. 150 (1972), we request dates and descriptions of any and all considerations or promises (

dy requests." As an initial matter, we take seriously our disclosure obligations, including those arising under Rule 16, Brady and its progeny, and Giglio v. United States, 405 U.S. 150 (1972) and its progeny, and we intend to comply fully with those obligations. We intend to do so irrespective of whe

are not aware of any authority requiring us to obtain and/or disclose this information. Request 11 — A Complete, Unredacted Copy of FBI 302 Bearing Bates Numbers SDNY_GM_00114982-00114993: The Government has produced this particular version of the document in the form in which it received the documen