Epstein Secrets

attack on credibility and motive involves plaintiff's sexual conduct does not prohibit its use." a at 1129. 9. In addition, in Delaney v. City of Hampton, 999 F. Supp. 794, 795 (ED. Va. 1997), plaintiff sued the city and a former co-worker for sexual harassment, which she claimed caused "severe emoti

93 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S MOTION PURSUANT TO FED. IL EVID. 412(c1 TO ADMIT EVIDENCE OF JANE DOE'S AND OTHER WITNESSES' SEXUAL HISTORY AND INCORPORATED MOTION FOR LEAVE TO FILE SUPPLEMENTAL MOTION PURSUANT TO RULE 412(0 REGARDING OTHER WITNESSES

14. If Jane Doe was having intercourse and oral sex with other males at the time she was allegedly going to Epstein's house, this would suggest that Jane Doc understood sex and sexuality and drew specific boundaries about what she would and would not do with Epstein. 32. It also contradicts Dr. Reed's o

regarding Jane Doe being sexually inexperienced Taira the frequency of sex with and the types of and naive, making her t " victim." Evidence of Jane Doe's relationship with demonstrates that Jane Doe sex they had. eventually became sexually experienced yet continued to go to Epstein's house. To con

ary evidence may not be relied on or considered in support of a motion for summary judgment. See, e.g., Hollywood Towers Condominium Ass'n, Inc. v. Hampton, 993 So. 2d 174, 175-176 (Fla. 4th DCA 2008) (unauthenticated photocopies of check, letter and bank statement attached to motion for summary judgme

perfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airplane travel in support of Jane Doe's Federal Rico claims and punitive damages (911 77-79); Epstein's interview with a New York newspaper reporter (9191 80-81); Epstein's alleged threat

., 166 F. Supp. 2d 805 (S.D.N.Y. 2001) 25 Franks v. Delaware, 438 U.S. 154 (1978) 20, 22 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 8, 15 Hampton v. United States, 425 U.S. 484 (1976) 20 In re WinNet R CISC, 2017 WL 1373918 (S.D.N.Y. No. 16MC484(DLC), Apr. 13, 2017) 24 Martindell v. Intl Te

g the government's ex parte request to modify the Jane Doe 43 Protective Order in part because the governme

., 166 F. Supp. 2d 805 (S.D.N.Y. 2001) 25 Franks v. Delaware, 438 U.S. 154 (1978) 20, 22 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 8, 15 Hampton v. United States, 425 U.S. 484 (1976) 20 In re WinNet R CISC, 2017 WL 1373918 (S.D.N.Y. No. 16MC484(DLC), Apr. 13, 2017) 24 Martindell v. Intl Te

80) (quoting McNabb, 318 U.S. at 345) (citing Elkins v. United States, 364 U.S. 206, 223 (1960); Rea v. United States, 350 U.S. 214, 216-17 (1956); Hampton v. United States, 425 U.S. 484, 495 (1976) (Powell, J., concurring in judgment)). A court should invoke its supervisory power of suppression when "t

g the government's ex parte request to modify the Jane Doe 43 Protective Order in part because the governme

lth Mgmt. Assocs., 166 F. Supp. 2d 805 2001) 25 Franks v. Delaware, 438 U.S. 154 (1978) 20, 22 v. Maxwell, 325 F. Supp. 3d 428 (. 2018) 8, 15 Hampton v. United States, 425 U.S. 484 (1976) 20 In re WinNet R CISC, 2017 WL 1373918 (MM. No. I6MC484(DLC), Apr. 13, 2017) 24 Martindell v. Intl Tel. &

80) (quoting McNabb, 318 U.S. at 345) (citing Elkins v. United States, 364 U.S. 206, 223 (1960); Rea v. United States, 350 U.S. 214, 216-17 (1956); Hampton v. United States, 425 U.S. 484, 495 (1976) (Powell, J., concurring in judgment)). A court should invoke its supervisory power of suppression when "t

g the government's ex parte request to modify the Jane Doe 43 Protective Order in part because the governme