Epstein Secrets

uring our investigation. To date, our team has not identified any photographs of among those seized. 7 As discussed below, we have identified one FedEx invoice from 2002 reflecting a package sent from Epstein's business address in Manhattan to home address in 2021.01.26 EFTA 00023125 EFTA0273123

led receiving multiple gifts from Epstein. received multiple s of lingerie orm Victoria's Secret, which were shipped to her home by either UPS or FedEx. had a New York address.? She also reca recalls seeing that the return address for these packages s that the packages either had Epstein's or Maxw

least one act in furtherance of the conspiracy to traffic while in the Southern District of New York. As to substantive sex trafficking offenses, the Second Circuit recently affirmed an SDNY sex trafficking conviction under 18 U.S.C. § 1591 where the minor victim testified that she was in SDNY when the defendan

ttorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express. This document was not filed using CM/ECF because it is being filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Sub

would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United

ttorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express. This document was not filed using CM/ECF because it is being filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Sub

would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United

claims 4 The Government understands from defense counsel that the CD containing a copy of this production, which the Government sent to the MDC via FedEx overnight shipping last week, has not been provided to the defendant. The Government has repeatedly asked MDC legal counsel to locate this CD and p

the S2 Indictment was returned on March 29, 2021, more than three months before trial. Indeed, it is telling that the defense cites no case in which the Second Circuit has held that a district court lacks the discretion to conduct a trial three months after a superseding indictment has been filed. Any such decisio

ach. 401 Telephone: Facsimile: E-mail: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August ? a 2007, the foregoing document was served via Federal Express on Attorney Roy Black and Attorney William Richey. This document was not filed using CIvI/ECF because it is being filed under seal. Assistant U.S.

ould effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EF

at Hoffenberg's direction, used it to pay Stratford's bills. Approximately three to five days later, Hoffenberg gave Dryfus a sealed, unaddressed, Federal Express package containing $26,000 in cash. Dryfus also used these funds to pay Stratford's bills, including Hoffenberg's $250 per month parking expenses.

t 1313. Hoffenberg suggests that United States v. Leonard, 50 F.3d 1152, 1158 (2d Cir.I995), suggests a high- er standard of proof. In Leonard, the Second Circuit instructed that "the district court should consider any evidence with a significant degree of probative value, and should rest its finding on evid

18 years of age and reside in Kings County, New York. On January 14, 2018, I served a true and correct copy of the annexed by mail in the custody of Federal Express directed to the following: Martin Weinberg 20 Park Place, Suite 1000 Boston, MA 02116 Karen Friedman Agnifilo Assistant District Attorney - New Yo

1-92 (3d Dep’t 1993) “a common-law presumption” favors public access to court records); /n re Application of National Broad. Co., 635 F.2d 945, 949 (2d Cir. 1980) (“[T]he common law right to inspect and copy judicial records is beyond dispute.”) (citation omitted). 13 4811-3721-9459v.3 3930033-000039 HO