Epstein Secrets

Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 1 of S U.S. Department of Justice United States Attorney Southern District of New York BY EMAIL USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE EILED:1 111 1 /21 The Honorable Alison J. Nathan United States Distr

formation. III. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes

Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00088802 Table of Contents PRELI

t understand why the Minor Victims continued to 3 In United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639 (E.D.N.Y. May 22, 2019), Judge Garaufis questioned whether an expert on grooming with experience focused on victims may have been able to testify reliably about how "perpetrators often use

Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 1 of S U.S. Department of Justice United States Attorney Southern District of New York BY EMAIL USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:11 ill /21 The Honorable Alison J. Nathan United States Distri

formation. III. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes

Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 1 of S U.S. Department of Justice United States Attorney Southern District of New York BY EMAIL USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:11 ill /21 The Honorable Alison J. Nathan United States Distri

formation. III. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yes