Epstein Secrets

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

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

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

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

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

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). Specifically, defendant seeks information regarding three individuals: Fred Ma