Epstein Secrets

Exhibit B, which is Dr. Hall's evaluation of Minor Victim-4, in accordance 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 brief and the attached exhibit are judicial documents subject to the common law presumption of access,

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

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 presumption of access, the proposed redactions

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

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 presumption of access, the proposed redactions

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

actions 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 the common law presumption of access, th

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

h 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 the common law presumption of access, th

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