produce these materials if and when the Court orders their production. Beyond the above materials, to date, the Government is unaware of any other Brady material regarding your client, but will provide timely disclosure if any such material comes to light. The Government will provide material under G

d Materials Anonymized Index (Produced Under Separate Cover) SDNY_00008123 Attorney's Eyes' Only The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government wishes to bring your attention to the following statements, which could constitute

USION 29 EFTA00031264 --- PAGE BREAK --- TABLE OF AUTHORITIES Cases 27 passim Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010) Brady v. Maryland, 373 U.S. 83 (1963) Color of Change v. United States Dep't of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dep't of Interior

uld be disclosed when defendants make a 7 EFTA00031274 --- PAGE BREAK --- demand for it. 267 F.3d at 146. The court held that as a general rule, Brady and its progeny do not require immediate disclosure of all impeachment material upon a defendant's request. Id. It found that the time required for

0-AT Document 35 Filed 04/24/20 Page 3 of 34 TABLE OF AUTHORITIES 27 passim Cases Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010) Brady v. Maryland, 373 U.S. 83 (1963) Color of Change v. United States Dep't of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dept of Interior

AGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 13 of 34 demand for it. 267 F.3d at 146. The court held that as a general rule, Brady and its progeny do not require immediate disclosure of all impeachment material upon a defendant's request. Id. It found that the time required for

NY 10022 ♦1 212 957 7600 phono www colsmipossoo corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request

rors, witnesses under examination, court reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the g

agazine and I have been on the cover like fourteen or fifteen times. I think I have the all-time record in the history of 7Zime magazine. Like if Tom Brady is on the cover it’s one time because he won the Super Bowl or something. I’ve been on fifteen times this year. I don’t think, Mike, that’s a record

na’s Secret ‘Magic Weapon’ for Worldwide Influence.” Financial Times. 26 Oct. 2017, http://www.ft.com /content/fb2b3934-b004-11e7-beba-5521c713abf4.; Brady, Anne-Marie. “Magic Weapons: China’s Political Influence Activities under Xi Jinping.” Wilson Center Kissinger Institute on China and the United Stat

ds, found that rats could be trained to push levers to obtain current delivery via electrodes in various parts of their brains. Shortly after, Joseph Brady, then of the Walter Reed Army Institute of Research, showed that squirrel monkeys would do the same. With depth electrodes attached to wires running

n, finding nothing to suggest the withholding of evidence material to the appellant's guilt or to his punishment. The court also expressed doubt that Brady was intended to apply to testimony before a grand jury. In Jackman v. State, 140 So.2d 627 (Fla. 3d DCA 1962), appellant Jackman contended the trial

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

J8RsEPSl I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that

cene.html? r=2 Sources “States of Bankruptcy, Part I: The Coming State Pensions Crisis”, Joint Economic Committee Republicans, Representative Kevin Brady and Senator Jim DeMint, December 8, 2011 “The Trillion Dollar Gap, Underfunded State Retirement Systems and the Roads to Reform”, Pew Center, Februa

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

considers unfavorable to Ms. Maxwell, begrudgingly EFTA00014671 --- PAGE BREAK --- The Honorable Alison J. Nathan May 12, 2021 Page 2 produce Brady material with various disclaimers such as "although the government is not obligated to do so" (Dkt. 269 pp. 8, 9), and obfuscate the importance of l

se was examining his diary, . . . he requested that this not be done." Id. While the parties were discussing how to review the diary, including for Brady material, the diary was returned to the witness. It was only given to the defense for examination after "roughly five days" in the witness's possess

entify the "other" overt acts ("the following overt acts, among others") referenced in ¶ 22 of the indictment. IV. Brady Material A. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, including Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976)

was legally obligated to do so. shows that the government has accept e accusers accounts without serious scrutiny. Given the ovenunent's ongoittti Brady obligations. it is unsettling that the government would simply acce Contrary to the government's assertion_ the defense has not abandoned our legal

ssurances of preservation -- requires a full factual record and, if appropriate, sanctions for the loss of the evidence. The Supreme Court held in Brady v. Maryland, 373 U.S. 83, 87 (1963), that "the suppression by the prosecution of evidence favorable to the accused upon request violates due proces

s listed on search inventories, please let us know, and we will make arrangements for you to do so. The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. Pursuant to those obligations, we are disclosing the information below. This disclosure should no

ng those statements are included in this production and are marked with control number USAO 002273. The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. Pursuant to those obligations, we are disclosing the information below. This disclosure should no

l be consideration of expiring tax provisions, House and Senate miscellaneous tax bills, and tax technical corrections. House Ways and Means Chairman Brady is opposed to addressing tax extender provisions this year, preferring to look forward to tax reform; that could also be the position taken on other