Epstein Secrets

ility to confer with prosecutorial authorities in other jurisdictions, namely the United States Attorney's Offices of the District of New Jersey and New York, which share jurisdiction and venue over the federal offenses potentially chargeable against 5 EFTA00177797 Case 9:08-cv-80736-KAM Document 189 E

d the issue in Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410 and did not see fit to recognize a privilege for plea negotiation communications. Neither the Rules of Evidence nor the Rules of Criminal Procedure, however, have ever dealt with specifying the privileges which will and will not be recognized; instead, they l

defendant intended to engage in sexual 31 EFTA00090757 activity for which the defendant could be charged with specific New Jersey, Pennsylvania, New York, and Canadian criminal offenses" (emphasis added)). Accordingly, the Court should give the jury the defense's requested limiting instruction.' V. T

data of other emails with the author identified). Such arguments are based on outdated stereotypes and reveal a reliance on character evidence that the Rules of Evidence specifically disallow. This Court should reject the belated, insufficient, improper argument that are direct evidence of the charged conspiracy,

Atterbury, Goldberger and Weiss-one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the Internet, I located the IRS returns of "The C.O.U.Q. Found

ANSCRIPTION EFTA00231639 Case 9:08-cv-80119-KAM 1 2 3 Document 180 Entered on FLSD Docket 06/24/2009 Page25of51 25 way that is proper under the Rules of Evidence and your rulings. The NPA has no limitation on his contesting damages above the minimum statutory amount. 4 The only thing that he has done is in

Atterbury, Goldberger and Weiss—one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the internet, I located the IRS returns of "The C.O.U.Q. Found

E TRANSCRIPTION EFTA00232759 Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 25 of 51 25 1 way that is proper under the Rules of Evidence and your 2 rulings. The NPA has no limitation on his contesting damages 3 above the minimum statutory amount. 4 The only thing that he has done i