Epstein Secrets

OB JECTIONS TO THE PRESENTENCE INVESTIGATION REPORT Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00156337 TABLE OF CONTENTS Page I. The 2003 Guidelines

eim Law Offices of Bobbi C. Stemheim Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

"coerce" minors to travel to engage in prohibited sexual conduct and "enticing" minors to engage in commercial sex acts. (S2 Ind. ¶¶ 12, 24, 27).1° Webster's Dictionary defines the word "entice" to mean "to attract artfully or adroitly or by arousing hope or desire; tempt" and the further explains that

ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B

advance the 3 search for truth. And here we have a conspiracy, and I'm using 4 that term not as a lawyer but as a layperson for this purpose. 5 Webster's defines to conspire means to join together in a 6 secret agreement to do an unlawful or wrongful act or an act 7 which becomes unlawful as a re

ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B

is whether admitting the evidence will advance the search for truth. and I'm using that term not as a lawyer but as a layperson for this purpose. Webster's defines Of course once you determine that something's relevant, you then have to consider possible prejudicial effect. Obviously this is a case

: In reply, your Honor, I think you can just see from the upset there what's going to be happening at this trial. This is the direct quote from Mr. Pagliuca. "Fantastical conspiracy". That's going to be the argument from the other side. They're obviously entitled to advance that argument. But that's wh

ence will advance the search for truth. And here we have a conspiracy, and I'm using that term not as a lawyer but as a layperson for this purpose. Webster's defines to conspire means to join together ina secret agreement to do an unlawful or wrongful act or an act which becomes unlawful as a result of