Epstein Secrets

f and seal 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 l

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

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 presumption of access

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

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 presumption of access

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

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 presumption o

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

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 presumption o

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

he 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 the common la

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

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 the common l

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