Epstein Secrets

review, the Government estimates that approximately one month remains before any final deferred prosecution agreements could be submitted to Judge Torres and publicly disclosed, including to the Times. The Government understands that its proposed schedule is not as expeditious as the Court initially

Case 1:20-cv-00833-PAE Document 52 (Ex Parte) Filed 04/28/21 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 April 28, 2021 Submitted Ex Pane and Under Seal By ECF The Honorable Paul A. Engelmayer

review, the Government estimates that approximately one month remains before any final deferred prosecution agreements could be submitted to Judge Torres and publicly disclosed, including to the Times. The Government understands that its proposed schedule is not as expeditious as the Court initially

Case 1:20-cv-00833-PAE Document 52 (Ex Parte) Filed 04/28/21 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 April 28, 2021 Submitted Ex Pane and Under Seal By ECF The Honorable Paul A. Engelmayer

eral Evidence § 702.02 [2] (2d ed. 2006)). Finally, even if the expert testimony is reliable, it must also be relevant. See, e.g., United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at *6 (S.D.N.Y. May 13, 2021). In this context, the testimony must "concern matters that the average juror i

Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00088802 Table of Contents PRELI