EFTA00027307Set 8
2020-04-2434p10,823w
Defense Requests for Additional Discovery Materials 4
ARGUMENT 7
I. Applicable Law 7
A. Brady & Giglio 7
B. Rule 16 8
II. Thomas is Not Entitled to Additional Materials ... Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010) 27
Brady v. Maryland, 373 U.S. 83 (1963) passim
Color of Change v. United States ... initial matter, the Government has satisfied its Rule 16, Brady, and Giglio obligations
and is not in possession of the additional materials that Thomas seeks. More importantly, Thomas
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027307.pdf
EFTA00031263Set 8
2011-01-3134p10,482w
Defense Requests for Additional Discovery Materials 4
ARGUMENT 7
I. Applicable Law 7
A. Brady & Giglio 7
B. Rule 16 8
II. Thomas is Not Entitled to Additional Materials ... Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010) 27
Brady v. Maryland, 373 U.S. 83 (1963) passim
Color of Change v. United States ... initial matter, the Government has satisfied its Rule 16, Brady, and Giglio obligations
and is not in possession of the additional materials that Thomas seeks. More importantly, Thomas
https://www.justice.gov/epstein/files/DataSet%208/EFTA00031263.pdf
EFTA00096232Set 9
2019-08-0116p5,202w
Jeffrey Epstein. No. 19-cr-00490
Defendant's Request for Particulars Discovery and Brady Material
Dear Ms. Comey, Ms. Moe, and Mr. Rossmiller:
We arc writing on behalf of Jeffrey ... from among the materials produced
pursuant to Mr. Epstein's other Rule 16 and Brady requests, both to enable
counsel to prepare effectively for trial and to afford Mr. Epstein ... from among the
materials produced pursuant to Mr. Epstein's other Rule 16 and Brady
requests.
EFTA00096234
August 1, 2019
Steptoe
11 I/ In • 101101001 LIP
Page 4
6. Relating
https://www.justice.gov/epstein/files/DataSet%209/EFTA00096232.pdf
EFTA00104411Set 9
23p6,234w
Punishments. 11
III. The Government Should Immediately Produce Accuser-4's Prior Statements as
Brady Material. 14
IV. The Court Should Grant Ms. Maxwell's Other Requested Relief. 16
CONCLUSION ... omission of Ms. Maxwell in her FBI interview is somehow not exculpatory Brady information,
and therefore they do not need to produce her prior statements to the defense until much ... closer to
trial. The government's inability to recognize obvious Brady material, and identify it as such,
reflects a persistent and troubling disregard for its obligations which the Court should
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104411.pdf
EFTA00029540Set 8
2021-07-1234p11,084w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029540.pdf
EFTA00085225Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00085225.pdf
EFTA00105663Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105663.pdf
EFTA00154640Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00154640.pdf
EFTA00092886Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00092886.pdf
EFTA00022091Set 8
2021-07-1234p11,082w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%208/EFTA00022091.pdf
EFTA00092755Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00092755.pdf
EFTA00104652Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104652.pdf
EFTA00103308Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103308.pdf
EFTA00103343Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103343.pdf
EFTA00090494Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00090494.pdf
EFTA00103273Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103273.pdf
EFTA00020261Set 8
2021-07-1234p11,082w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%208/EFTA00020261.pdf
EFTA00103238Set 9
2021-07-1234p11,087w
also seeks accelerated disclosure of the
Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator
statements, and Rule 404(b) material. Based on the Government ... disclosures.
A. The Court accepts the Government's representations that it has disclosed all
Brady and Giglio Material
The Supreme Court's decisions in Brady v. Maryland ... require the Government to disclose to defendants certain
evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under
Giglio, the Government has a duty to produce
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103238.pdf