Epstein Secrets

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

conviction to determine the present punishment or immigration consequences would encounter logistical and constitutional obstacles. Id. (noting an Apprendi problem and "daunting practical difficulties and potential unfairness"). None of those concerns is present here, where the relevant facts will be p

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

conviction to determine the present punishment or immigration consequences would encounter logistical and constitutional obstacles. Id. (noting an Apprendi problem and "daunting practical difficulties and potential unfairness"). None of those concerns is present here, where the relevant facts will be p

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,

r conviction to determine the present punishment or immigration consequence would encounter logistical and constitutional obstacles. Id. (noting an Apprendi problem and "daunting practical difficulties and potential unfairness"). None of those concerns are present here, where the relevant facts will be

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

conviction to determine the present punishment or immigration consequences would encounter logistical and constitutional obstacles. Id. (noting an Apprendi problem and "daunting practical difficulties and potential unfairness"). None of those concerns is present here, where the relevant facts will be p

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

U.S. 270, 127 S.Ct. 56, 166 L.Ed.2d 856 (2007), Ring I. Arizona, and related Supreme Court precedents, urges us reach a different conclusion. In Apprendi New Jersey, 530 U.S. 466 120 S.Ct. 348, 147 L.Ed.2d 435 (2000), the Su- preme Court emphasized that "Ulf a State makes an increase in a defendants