Epstein Secrets

") (collectively "Defendants") submit this memorandum in support of their motion to dismiss the First Amended Complaint ("FAC") filed by plaintiff Jane Doe ("Plaintiff') pursuant to Fed.R.Civ.P. 12(b)(2) and (6). The FAC represents the Plaintiff's second unsuccessful bite at the apple. On January 26,

f slavery whose victims are predominantly women and children, to ensure just and effective punishment of traffickers, and to protect their victims." H.R. Conf. Rep. 106-939 (2000). Among other specific factual findings reached by Congress when it was drafting Section 1591, Congress found as follows: 10

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

t of 1996, entitled "Obscenity and Violence", after the Senate Judiciary Committee held a hearing regarding child endangerment via the intemet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States I Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005); see also K. Seto, "Note: How Should Legisl

t there, in facts far different from ose presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in Prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

of 1996, entitled "Obscenity and Violence", after the Senate Judiciary Committee held a hearing regarding child endangerment via the internet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States' Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005); see also K. Seto, "Note: How Should Legisla

court in Doe'. Epstein, No. 9:08- cv-80I19-KAM (S.D. Fla.). Brunel's attorney asked counsel for Jane Doe to postpone the scheduled deposition date. Jane Doe's counsel agreed, and then Brunel's attorney cancelled the rescheduled deposition date. Brunel's counsel represented that Brunel was outside the count

of 1996, entitled "Obscenity and Violence", after the Senate Judiciary Committee held a hearing regarding child endangerment via the Internet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States ' Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005); see also K. Seto, "Note: How Should Legis

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

R. Evid. 801 210 N.Y. R.P.C. 3.7(b) 166 Rule 14 157 Rule 404(b) 186 Other Authorities 149 Cong. Rec. S 5137 30 149 Cong. Rec. S 5147 30 H.R. Conf. Rep. No. 108-66 29 Positivism and the Separation of Law and Morals, 71 Harv. L. Rev. 593 (1958) 130 Sexual Abuse Prosecutions, 77 J. Crim. L.

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

R. Evid. 801 210 N.Y. R.P.C. 3.7(b) 166 Rule 14 157 Rule 404(b) 186 Other Authorities 149 Cong. Rec. S 5137 30 149 Cong. Rec. S 5147 30 H.R. Conf. Rep. No. 108-66 29 Positivism and the Separation of Law and Morals, 71 Harv. L. Rev. 593 (1958) 130 Sexual Abuse Prosecutions, 77 J. Crim. L.

dge Netburn's Order On or about April 9, 2019, the Government advised Judge Netburn, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. 1). Subsequently,

Criminal Procedure 8(a) 138 Federal Rule of Criminal Procedure 16 182 N.Y. R.P.C. 3.7(b) 148 Rule 14 139 Rule 404(b) 168 Other Authorities H.R. Conf. Rep. No. 108-66 29 Positivism and the Separation of Law and Morals, 71 Harv. L. Rev. 593 (1958) 130 Sexual Abuse Prosecutions, 77 J. Crim. L.

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

t of 1996, entitled "Obscenity and Violence", after the Senate Judiciary Committee held a hearing regarding child endangerment via the intemet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States' Searcy, 418 F.3d 1193, 1197 (l Cir. 2005); see also K. Seto, "Note: flow Should Legislat

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in Prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

of 1996, entitled "Obscenity and Violence", after the Senate Judiciary Committee held a hearing regarding child endangerment via the internet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States v. Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005); see also K. Seto, "Note: How Should Legis

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

R. Evid. 801 210 N.Y. R.P.C. 3.7(b) 166 Rule 14 157 Rule 404(b) 186 Other Authorities 149 Cong. Rec. S 5137 30 149 Cong. Rec. S 5147 30 H.R. Conf. Rep. No. 108-66 29 Positivism and the Separation of Law and Morals, 71 Harv. L. Rev. 593 (1958) 130 Sexual Abuse Prosecutions, 77 J. Crim. L.