Epstein Secrets

s proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored t

nty to these witnesses in advance of their testimony. ' The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumptio

whom the Court has authorized to testify using pseudonyms or their first names. EFTA00010038 --- PAGE BREAK --- Page 3 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) EFTA00010039

proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter motion is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tail

' The Government moves to file a redacted version this letter motion. The proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter motion is a judicial document subject to the common law pr

For the foregoing reasons, the Court should determine that the Minor Victims' birth certificates are self-authenticating. Respectfully submitted, DAMIAN WILLIAMS United States Attorney by: Is/ ssis an ni e a es Attorneys cc: Counsel of Record (by email) EFTA00010110

proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter motion is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tail

' The Government moves to file a redacted version this letter motion. The proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter motion is a judicial document subject to the common law pr

For the foregoing reasons, the Court should determine that the Minor Victims' birth certificates are self-authenticating. Respectfully submitted, DAMIAN WILLIAMS United States Attorney by: Is/ Assistant United States Attorneys cc: Counsel of Record (by email) EFTA00010116

proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's request to charge is a judicial document subject to the common law presumption of access, the proposed redactions

vernment has proposed the only redactions in the Request to Charge. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's request to charge is a judicial document subject to t

18881 --- PAGE BREAK --- Page 2 that was not itself publicly docketed and therefore is submitting Exhibit A under seal. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ MIE Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) EFTA00018882

posed testimony is relevant. See Dauber! v. Merrell Dow Pharm., Inc., 509 U.S. 579, 592 (1993); Nimely v. City of New York, 414 F.3d 381, 396 n.11 (2d Cir. 2005). "Expert testimony which does not relate to any issue in the case is not relevant and, ergo, non-helpful." Daubers, 509 U.S. at 591 (internal

expert notice, which the Court should order the defense to provide forthwith. Dated: November 15, 2021 New York, New York Respectfully submitted, DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: /s/ Assistant United States Attorneys 26 EFTA00024981

discovery in the broadest terms." Bowman Dairy Co. v. United States, 341 U.S. 214, 220 (1951); see also United States v. Purin, 486 F.2d 1363, 1368 (2d Cir. 1973) ("A subpoena duces tecum in a criminal case is not intended as a means of discovery."). It is not sufficient for a party to show only that th

d by Nixon. 418 U.S. at 700. III. Conclusion For the foregoing reasons, the Court should quash the defendant's subpoena.? Respectfully submitted, DAMIAN WILLIAMS United States Attorney by:mr _ Assistant United States Attorneys cc: Counsel of Record (by email) In the event the Court does not quash the sub

the Court under seal by email with proposed redactions. The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's motions in limine are judicial documents subject to t

ctfully requests that the Court permit the Government to publicly file its motions in limine with its proposed redactions. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense counsel (By ECF) EFTA00027705

nty to these witnesses in advance of their testimony. ' The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although this letter is a judicial document subject to the common law presumptio

whom the Court has authorized to testify using pseudonyms or their first names. EFTA00010041 --- PAGE BREAK --- Page 3 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: Cc: Defense Counsel (By ECF) Assistant United States Attorneys Southern District of New York EFTA00010042