Epstein Secrets

trial. Fed. R. Crim. P. 17(c)(1). Most district courts in the Second Circuit, including this Court, apply the analysis set forth in United States v. Nixon, 418 U.S. 683, 699-700 (1974). See United States v. Pena, No. 15-CR-551 (A.1N), 2016 WL 8735699, at *1 —2 (S.D.N.Y. Feb. 12, 2016). The party reque

I. Background On October 11, 2021, the government began producing 3500 material to the defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court

trial. Fed. R. Crim. P. 17(c)(1). Most district courts in the Second Circuit, including this Court, apply the analysis set forth in United States v. Nixon, 418 U.S. 683, 699-700 (1974). See United States v. Pena, No. 15-CR-551 (A.1N), 2016 WL 8735699, at *1 —2 (S.D.N.Y. Feb. 12, 2016). The party reque

I. Background On October 11, 2021, the government began producing 3500 material to the defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court

subpoena seeks information that is largely (if not entirely) inadmissible under Federal Rule of Evidence 408, it fails the test in United States v. Nixon, 418 U.S. 683, 702 (1974). Maxwell also seeks to subpoena statements of a witness or prospective witness that are not subject to subpoena under Fede

ative support" that the administrator may consider in evaluating claims." Maxwell also mischaracterizes the Protocol when she says that it "rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse."18 This is inaccurate. As the Protocol makes clear, the existence of "lawsuit[s], l

Nersesian, 824 F.2d 1294 (2d Cir. 1987) 233 EFTA00099959 United States v. Nitcche, 843 F. Supp. 2d 4 (D.D.C. 2011) 201, 202 United States v. Nixon, 418 U.S. 683 (1974) 282 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 WL 140966 (S.D.N.Y. Jan. 11, 2008) 164 United States v. Okwumabua,

As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unswom assertions as to vague generalities" that witnesses, "if alive, would give testimony

ian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA00077624 United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011) 201, 202 United States v. Nixon, 418 U.S. 683 (1974) 282 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 WL 140966 (S.D.N.Y. Jan. 11, 2008) 164 United States v. Okwumabua,

As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony

ian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA00039439 United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011) 201, 202 United States v. Nixon, 418 U.S. 683 (1974) 282 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 WL 140966 (S.D.N.Y. Jan. 11, 2008) 164 United States v. Okwumabua,

As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony

150 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 154 United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011) 136 United States v. Nixon, 418 U.S. 683 (1974) 190 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 WL 140966 (S.D.N.Y. Jan. 11, 2008) 112 United States v. Okwumabua,

As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony

ian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA00103017 United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011) 201, 202 United States v. Nixon, 418 U.S. 683 (1974) 282 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 WL 140966 (S.D.N.Y. Jan. 11, 2008) 164 United States v. Okwumabua,

As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony