Epstein Secrets

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys 212 EFTA00103237

ed. (Def. Mot. 9 at 6). As set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aff."), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pen

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: /s Assistant United States Attorneys (212) 637-2225 212 EFTA00100179

ed. (Def. Mot. 9 at 6). As set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aff."), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pen

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00077844

ed. (Def. Mot. 9 at 6). As set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aft"), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pend

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00039659

ed. (Def. Mot. 9 at 6). As set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aft"), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pend

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 211 EFTA00095303

igible for jury service); Rioux, 97 F.3d at 657 ("We conclude that the 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin Aft"), which was prepared for the defense in United States v. Balde, 20 Cr. 281 (KPF), where a similar motion is currently pending