Epstein Secrets

Cir. 2007) 251 xix EFTA00077625 United States v. Rahimi, No. 16 Cr. 760 (RMB), 2017 WL 2984169 (S.D.N.Y. June 22, 2017) 225 United States v. Rahman, 189 F.3d 88 (2d Cir. 1999) 154 United States v. Rajaratnam, No. 09 Cr. 1184 (RJH), 2010 WL 4867402 (S.D.N.Y. Nov. 24, 2010) 172 United States

case. AUSA-1 also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00077698 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st

outrageous 105 EFTA00077737 investigatory conduct is very heavy, see United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997). United States v. Rahman, 189 F.3d 88, 131 (2d Cir. 1999); United States v. Al Kassar, 660 F.3d 108, 121 (2d Cir. 2011) ("Generally, to be `outrageous,' the government's inv

udge Netburn's Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently,

Cir. 2007) 251 xix EFTA00039440 United States v. Rahimi, No. 16 Cr. 760 (RMB), 2017 WL 2984169 (S.D.N.Y. June 22, 2017) 225 United States v. Rahman, 189 F.3d 88 (2d Cir. 1999) 154 United States v. Rajaratnam, No. 09 Cr. 1184 (RJH), 2010 WL 4867402 (S.D.N.Y. Nov. 24, 2010) 172 United States

case. AUSA-1 also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00039513 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st

outrageous 105 EFTA00039552 investigatory conduct is very heavy, see United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997). United States v. Rahman, 189 F.3d 88, 131 (2d Cir. 1999); United States v. Al Kassar, 660 F.3d 108, 121 (2d Cir. 2011) ("Generally, to be `outrageous,' the government's inv

udge Netburn's Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently,

den of establishing outrageous investigatory conduct is very heavy, see United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997). United States v. Rahman, 189 F.3d 88, 131 (2d Cir. 1999); United States v. Al Kassar, 660 F.3d 108, 121 (2d Cir. 2011) ("Generally, to be `outrageous,' the government's inv

INIMIIIIM the definfrOn the defendant's motion for summary judgment. (See 15 Civ. 7443 (LAP), Dkt. No. 542-4). Giuffre has since self-identified as Jane Doe #3. (See id., Dkt. No. 23 n.2). 117 EFTA00095209 As described in the preceding section, in the fall of 2015, Giuffre sued the defendant for defa

Cir. 2007) 251 xix EFTA00103018 United States v. Rahimi, No. 16 Cr. 760 (RMB), 2017 WL 2984169 (S.D.N.Y. June 22, 2017) 225 United States v. Rahman, 189 F.3d 88 (2d Cir. 1999) 154 United States v. Rajaratnam, No. 09 Cr. 1184 (RJH), 2010 WL 4867402 (S.D.N.Y. Nov. 24, 2010) 172 United State

case. AUSA- I also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00103091 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st

outrageous 105 EFTA00103130 investigatory conduct is very heavy, see United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997). United States v. Rahman, 189 F.3d 88, 131 (2d Cir. 1999); United States v. Al Kassar, 660 F.3d 108, 121 (2d Cir. 2011) ("Generally, to be `outrageous,' the government's inv

udge Netburn's Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently,

al may cast such doubt on the fairness of the proceedings that a new trial is warranted, even if no ( ngle error requires reversal. United States Rahman, 189 F.3d 88 145 (41 ir.1999); see also United States I. Salameh, 152 F.3d 88, 157 (2d Cir.1998). [45] Nonetheless, not every error- whether alo

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO