Epstein Secrets

that "the defense will receive notice of any co-conspirator statements that the Government may seek to introduce through witness statements" in its Jencks Act production. (Gov't Opp. at 192, Dkt. No. 204). The Court denied the motion, explaining that the Court lacked the power to order pretrial discl

"necessary to complete the story of the crime on trial." United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012) ("Robinson argued at trial that Jane Doe was his `girlfriend' and that he had no control over her prostitution activities. Evidence that Robinson was in the prostitution business and contro

re-interviewed some of the girls, but limited their questions to "new" topics, such as the specific means of contact, to avoid creating inconsistent Jencks materials. The agents also delved into Epstein's history and interviewed others and obtained records to corroborate the girls' stories. FBI also in

fighting at school because the other girl accused Jane Doe #2 of being a prostitute, one of the school principals intervened. The principal searched Jane Doe #2's purse and found $300 cash. The principal asked Jane Doe #2 where the money came from. Jane Doe #2 initially claimed that she earned the money w

e-interviewed some of the girls, but limited their questions to "new" topics, such as the specific means of contact, to avoid creating inconsistent Jencks materials. The agents also delved into Epstein's history and interviewed others and obtained records to corroborate the girls' stories. FBI also in

the overt acts and substantive allegations related to each Jane Doe because the indictment has been revised to group the overt acts related to each Jane Doe. 'Each of the airplanes is held in a separate "shell corporation," JEGE, Inc., and Hyperion Air, Inc. Epstein is the sole shareholder in both of th

ed that, when defense counsel elected to put his investigator on the witness stand at trial, he must turn over the investigator's report pursuant to Jencks, but defense counsel can redact the report to only disclose that portion of the report that relates to the investigator's testimony. 7 EFTA006001

obtained from the U.S. Attorney's Office or the U.S. Department of Justice. Rather, they were obtained from counsel for Jeffrey Epstein pursuant to Jane Doe # 1 's civil suit against Mr. Epstein, to which the United States was not a party. Thus, the United States has never had the opportunity to litigat

ed that, when defense counsel elected to put his investigator on the witness stand at trial, he must turn over the investigator's report pursuant to Jencks, but defense counsel can redact the report to only disclose that portion of the report that relates to the investigator's testimony. 7 EFTA006570

obtained from the U.S. Attorney's Office or the U.S. Department of Justice. Rather, they were obtained from counsel for Jeffrey Epstein pursuant to Jane Doe # 1 's civil suit against Mr. Epstein, to which the United States was not a party. Thus, the United States has never had the opportunity to litigat

on probable cause, the court commonly will schedule a consolidated preliminary and detention hearing at which the prosecution must make available "Jencks" statements. If a hup://10.173.2.12/usao/cousa/olc/usaboolddrug/26drug.lum 4/10/2008 EFTA00191628 Federal Narcotics Prosecutions - Chapter 26 P

8's eighteenth birthday, and when Jane Doe #19 was seventeen years old. [NB: The police report describes a pattern of activity, including dates when Jane Doe #18 was seventeen years old.] Neither Jane Doe #18 nor #19 ever returned to Epstein's home. Although we have not yet obtained Jane Doe #18's teleph

statements of a witness on the subject of his testimony are the kind of evidentiary matter to which an adversary is entitled. F198. The Court in Jencks quoted the language of Mr. Clgef Justice Marshall in United State Burr, 25 Fed.Cas., No. 14,694, pp. 187, 191 (Va. 1807): "Now, if a paper be in

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

ts, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

ttorney Edwards who was informed of these developments and who received both the initial and corrected victim notification letters that were sent to Jane Doe #1. 12. In accordance with the Court's instructions at the status conference of August 14, 2008 and the terms of the Protective Order entered by t

ts, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

ttorney Edwards who was informed of these developments and who received both the initial and corrected victim notification letters that were sent to Jane Doe #1. 12. In accordance with the Court's instructions at the status conference of August 14, 2008 and the terms of the Protective Order entered by t

e-interviewed some of the girls, but limited their questions to "new" topics, such as the specific means of contact, to avoid creating inconsistent Jencks materials. The agents also delved into Epstein's history and interviewed others and obtained records to corroborate the girls' stories. FBI also in

m trash pulls, the flight manifests from Epstein's private lanes, and testimony from the girls about how the appointments were made. So, if called Jane Doe ake an appointment on January 1st; Epstein traveled to Florida on January 2nd; and Weaned Jane Doe #12 on 18 EFTA02857620 January 3rd (when they wer

JD#2 was 14 when she was brought to JE's home in 2001. JD#1 told JD#2 that she could make $300 for giving a massage to a man in Palm Beach. JD#1 2 Jane Doc #1 was brought to JE's home by Ghislaine Maxwell after Maxwell met her at Mar a Lago. Jane Doe #1 was 15 at the time of her first contact with JE an