Epstein Secrets

k indictment because they arose out of "the same conspiratorial agreement that underlay the charges dismissed in the Eastern District." Id. at 672. The Second Circuit rejected this argument finding that, as a general rule, a plea agreement only binds the prosecutor's office that entered into the agreement, unless

he Double Jeopardy Clause, and (3) grant her other requested relief. Dated: May 7, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

074492 prejudicial to Ms. Maxwell and will mislead the jury into believing that the alleged sex acts between Epstein and Accuser-3 were unlawful.; The Second Circuit takes an "inclusionary approach" to Rule 404(b) evidence, which admits "other act" evidence "that does not serve the sole purpose of showing the def

Accuser-3's testimony that includes the points discussed above. Dated: October 18, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

cult? (6) Do the defendants have limited funds with which to investigate and prepare their defense? Rueb, 2001 WL 96177, at *7-8 (citation omitted). The Second Circuit, however, has not adopted these factors, nor do they constitute an exhaustive list of factors that the Court may consider in determining whether to

• For the reasons set forth above, we respectfully submit that the Court should grant Ms. Maxwell's motion. Respectfully submitted, /s/ Christian R. Everdell Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 cc: All counsel of record (via E

cult? (6) Do the defendants have limited funds with which to investigate and prepare their defense? Rueb, 2001 WL 96177, at *7-8 (citation omitted). The Second Circuit, however, has not adopted these factors, nor do they constitute an exhaustive list of factors that the Court may consider in determining whether to

. For the reasons set forth above, we respectfully submit that the Court should grant Ms. Maxwell's motion. Respectfully submitted, /s/ Christian R. Everdell Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All counsel

087787 prejudicial to Ms. Maxwell and will mislead the jury into believing that the alleged sex acts between Epstein and Accuser-3 were unlawful.; The Second Circuit takes an "inclusionary approach" to Rule 404(b) evidence, which admits "other act" evidence "that does not serve the sole purpose of showing the def

Accuser-3's testimony that includes the points discussed above. Dated: October 18, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP New York, NY Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO

e problems. Alternatively, or perhaps with the unknown stipulations, the government suggests prejudice could be avoided by jury instructions. It is The Second Circuit has adopted an inclusionary approach to other act evidence under Rule 404(b), which allows such evidence to be admitted for any proper purpose other

erance of and Separate Trial on Counts Five and Six of the Superseding Indictment upon the following: s . U.S. Attorne 's Office SDNY s/ Christian R. Everdell 13 EFTA00097328

e problems. Alternatively, or perhaps with the unknown stipulations, the government suggests prejudice could be avoided by jury instructions. It is The Second Circuit has adopted an inclusionary approach to other act evidence under Rule 404(b), which allows such evidence to be admitted for any proper purpose other

erance of and Separate Trial on Counts Five and Six of the Superseding Indictment upon the following: s . U.S. Attorne 's Office SDNY s/ Christian R. Everdell 13 EFTA00097375