Epstein Secrets

Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 6 of 6 The Honorable Alison J. Nathan October 14, 2020 Page 6 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq. EFTA00092721

14, 2020 Page 6 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim,

when the government has made a sufficient showing that disclosure may lead to witness intimidation or threats to their safety. See United States v. Urena, 989 F. Supp. 2d 253, 262-63 (S.D.N.Y. 2013) (collecting cases). The government has done neither here. The government has not made any showing that

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

ule 16 of making "a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

Rule 16 of making "a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

Rule 16 of making "a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

ule 16 of making "a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

when the government has made a sufficient showing that disclosure may lead to witness intimidation or threats to their safety. See United States v. Urena, 989 F. Supp. 2d 253, 262-63 (S.D.N.Y. 2013) (collecting cases). The government has done neither here. The government has not made any showing that

- Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 6 of 6 The Honorable Alison J. Nathan October 14, 2020 Page 6 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq. EFTA00023334