Epstein Secrets

arte2urfeneleta off Ficarvaatkat Pag6/2Ct1131.5Page 2 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JU

to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three

y gave a straightforward account of relevant background information based on [the expert's] own knowledge and experience" (quoting United States v. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017)); United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021) (holding that expert testimony on grooming wa

ich evidence of prior crimes, wrongs, or acts is admissible for any purpose other than to show a defendant's criminal propensity." United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006) (internal quotation marks omitted). Where the defendant claims her conduct has an innocent explanation, the admiss

arte2urfeneleta off Ficarvaatkat Pag6/2Ct1131.5Page 2 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JU

to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three

Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE I JOHNSON UP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that will effectively gua

to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three

2014) 140 Int'l Equity !nvs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 111 Johnson v. United States, 520 U.S. 461 (1997) 200 Kungys v. United States, 485 U.S. 759 (1988) 222 Landgraf v. USI Film Products, 511 U.S. 244 (1994)

ited States v. Page, 657 F.3d 126 (2d Cir. 2011) 205, 209, 210, 220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.

2014) 140 Int'l Equity !nvs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 111 Johnson v. United States, 520 U.S. 461 (1997) 200 Kungys v. United States, 485 U.S. 759 (1988) 222 Landgraf v. USI Film Products, 511 U.S. 244 (1994)

ited States v. Page, 657 F.3d 126 (2d Cir. 2011) 205, 209, 210, 220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.

. 2013) 98 Int'l Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 79 Johnson v. United States, 520 U.S. 461 (1997) 135 vi EFTA00095073 Kungys v. United States, 485 U.S. 759 (1988) Landgraf v. US! Film Products, 148 5

United States v. Page, 657 F.3d 126 (2d Cir. 2011) 138, 140, 147 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 165 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 165 United States v. Payner, 447 U.S. 727 (1980) 82, 110 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.Y. 201

except in the most extraordinary circumstances." Forde, 740 F.Supp.2d at 412 (citing Gaudin, 515 U.S. at 522-23). As the Supreme Court explained in Johnson v. United States, 520 U.S. 461 (1997), "there is no doubt that materiality is an element of perjury under § 1623," and its precedent "therefore dict

relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, 165 EFTA00095257 uncharged

was convicted in February along with Kenneth Johnson, 63, who was convicted of two of the murders in the aid of racketeering, along with conspiracy. Johnson was also sentenced to life in federal prison, where there is no parole. The article mentioned that in addition, John Stinson, 70, who was also serv

gnated meeting location, he was met by members of the FBI's Child Exploitation and Human Trafficking Task Force and was arrested. Starting in April, Paulin used an undisclosed app and "was communicating with someone who was believed to be the father of the 7- and 9-year-old boys," a police booking affi

except in the most extraordinary circumstances." Forde, 740 F.Supp.2d at 412 (citing Gaudin, 515 U.S. at 522-23). As the Supreme Court explained in Johnson v. United States, 520 U.S. 461 (1997), "there is no doubt that materiality is an element of perjury under § 1623," and its precedent "therefore dict

relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, uncharged acts are admissible