Document 68

Case 1:19-cr-00490-RMB Document 68 Filed 08/04/25 Page 1 of 2 MEMO ENDORSED August 4, 2025 Page 1 VIA EMAIL TO JUDGE BERMAN: Hon. Richard M. Berman, U.S.D.J. United States District Court Southern District of New York 500 Pearl Street New York, New York 10007-1312 Re: USA vs. Epstein, 1:19-cr-00490-RMB Dear Hon. Judge Berman: As a suffering victim of Epstein and his co-conspirators, I would like to highlight some things that stand out to me and for many reasons on the latest 'memo' written by an anonymous member of the DOJ. One, I am not sure the highest priority here is the victims, justice for the victims or combatting child exploitation, or at least I do not feel this way. If there was justice for the victims we would see some kind of accountability for the years they allowed this horrible human being, if you can call him that, to prey on underage and young girls while jet-setting around the world with high-profile individuals and/or entrapping his victims in his various mansions and/or his notorious private island. And to make matters more severe continued to traffic, rape and assault victims while on prison work-release and/or even after being a registered sex offender for about a decade. Rather, I feel like the DOJ's and FBI's priority is protecting the "third-party", the wealthy men by focusing on scrubbing their names off the files of which the victims "know who they are". To learn that our own president has utilized thousands of agents to protect his identity and these high-profile individuals is monumentally mind-blowing. That is their focus? Wow! Two, the fact that he "Killed himself" in prison leaves us all empty, without answers, without resolution, with the ongoing conspiracy that will never die. I ask myself every day, what happened? Did he really "Kill himself"? Is he still alive? Where is he buried? Why didn't we get to see his dead body? This all leaves me fearful, angry and rightfully devastated and damaged. Three, the latest attention on the "Epstein Files", the "Client List" is OUT OF CONTROL and the ones that are left to suffer are not the high-profile individuals, IT IS THE VICTIMS. Why the lack of concern in handling such sensitive information for the victims sake? I appreciate your time reading my short thoughts and feeling and my anxiety and frustration is NOT aimed at you, obviously. It is aimed at the very government here, the ones asking to release these transcripts, exhibits, etc., of which the victims are not privy to while they have concluded that there is nothing more to see on the files they hold. Yet no one has seen them, but them. I am beside myself. I think what I would request from you, your honor, is to consider having an approved third-party review these documents to ensure that NO victims names or likenesses are revealed through this release. It is imperative with the scrutiny over this media frenzy that the victims are completely and entirely protected. SO ORDERED: Date: 08/04/25 Richard M. Berman, U.S.D.J. DOJ-OGR-00000757 --- PAGE BREAK --- Case 21-770, Document 68, 04/27/2021, 3087718, Page1 of 1 21-58-cr (L), 21-770-cr United States v. Maxwell United States Court of Appeals FOR THE SECOND CIRCUIT At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 27th day of April, two thousand twenty-one. PRESENT: PIERRE N. LEVAL, RAYMOND J. LOHIER, JR., RICHARD J. SULLIVAN, Circuit Judges. United States of America, v. Appellee, 21-58-cr (L) 21-770-cr Ghislain Maxwell, AKA Sealed Defendant 1, Defendant-Appellant. Defendant-Appellant Ghislaine Maxwell appeals from orders of the District Court entered December 28, 2020 and March 22, 2021, which denied her renewed requests for bail pending trial. See Dkts. 1, 20. Upon due consideration, it is hereby ORDERED that the District Court's orders are AFFIRMED and that Appellant's motion for bail, or in the alternative, temporary pretrial release pursuant to 18 U.S.C. § 3142(i), Dkt. 39, is DENIED. During oral argument, counsel for Appellant expressed concern that Appellant was improperly being deprived of sleep while incarcerated. To the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court. FOR THE COURT: Catherine O'Hagan Wolfe, Clerk of Court Catherine O'Hagan Wolfe DOJ-OGR-00001406 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 68 Filed 11/05/20 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK IN RE: FEDERAL RULE OF CRIMINAL PROCEDURE 5(F) ORDER ALISON J. NATHAN, United States District Judge: This Order is entered, pursuant to Federal Rule of Criminal Procedure 5(f) and the Due Process Protections Act, Pub. L. No 116–182, 134 Stat. 894 (Oct. 21, 2020), to confirm the Government’s disclosure obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, and to summarize the possible consequences of violating those obligations. The Government must disclose to the defense all information “favorable to an accused” that is “material either to guilt or to punishment” and that is known to the Government. Id. at 87. This obligation applies regardless of whether the information would itself constitute admissible evidence. The Government shall disclose such information to the defense promptly after its existence becomes known to the Government so that the defense may make effective use of the information in the preparation of its case. As part of these obligations, the Government must disclose any information that can be used to impeach the trial testimony of a Government witness within the meaning of Giglio v. United States, 405 U.S. 150 (1972), and its progeny. Such information must be disclosed sufficiently in advance of trial in order for the defendant to make effective use of it at trial or at such other time as the Court may order. The foregoing obligations are continuing ones and apply to materials that become known to the Government in the future. Additionally, if information is otherwise subject to disclosure, it must be disclosed regardless of whether the Government credits it. DOJ-OGR-00001816 --- PAGE BREAK --- Case 1:19-cr-00490-RMB Document 68 Filed 08/04/25 Page 2 of 2 August 4, 2025 Page 2 Thank you so much for your time. I have attached the portion of the DOJ's memo and link to their statement. [Consistent with prior disclosures, this review confirmed that Epstein harmed over one thousand victims. Each suffered unique trauma. Sensitive information relating to these victims is intertwined throughout the materials. This includes specific details such as victim names and likenesses, physical descriptions, places of birth, associates, and employment history. One of our highest priorities is combatting child exploitation and bringing justice to victims. Perpetuating unfounded theories about Epstein serves neither of those ends. To that end, while we have labored to provide the public with maximum information regarding Epstein and ensured examination of any evidence in the government's possession, it is the determination of the Department of Justice and the Federal Bureau of Investigation that no further disclosure would be appropriate or warranted.] https://www.justice.gov/opa/media/1407001/dl?inline DOJ-OGR-00000758 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 68 Filed 11/05/20 Page 2 of 2 In the event the Government believes that a disclosure under this Order would compromise witness safety, victim rights, national security, a sensitive law-enforcement technique, or any other substantial government interest, it may apply to the Court for a modification of its obligations, which may include in camera review or withholding or subjecting to a protective order all or part of the information otherwise subject to disclosure. For purposes of this Order, the Government includes all current or former federal, state, and local prosecutors, law-enforcement officers, and other officers who have participated in the prosecution, or investigation that led to the prosecution, of the offense or offenses with which the defendant is charged. The Government has an affirmative obligation to seek from such sources all information subject to disclosure under this Order. If the Government fails to comply with this Order, the Court, in addition to ordering production of the information, may: (1) specify the terms and conditions of such production; (2) grant a continuance; (3) impose evidentiary sanctions; (4) impose sanctions on any responsible lawyer for the Government; (5) dismiss charges before trial or vacate a conviction after trial or a guilty plea; or (6) enter any other order that is just under the circumstances. SO ORDERED. Dated: November 5, 2020 New York, New York ALISON J. NATHAN United States District Judge