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riod and say, You 25 know, I should have realized there was something that were being prosecuted on behalf of throe young 1 woman: M., B.N. and Jane Doe. And w➢ will refer to them when I talk to you about them in that ➢ame way, 4 referring to sham by those initial➢ and that 5 pseudonym. 4 Desc
if it happened it's relevant to 5 proving that it had happened to your client. 4 The whole point is to prove that it / happened to your client, Donau.* it happened to • other people. And the circumstances, if they can be • similar, that helps as wall. 10 II • You spoke about modus operandi.
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
Thus, the defendant's claim that she no longer has access to certain evidence is not a proper basis to dismiss the Indictment. See United States v. Donau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973) ("A bare allegation that records have been lost or destroyed, which might relate Ig The Government notes t
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
Thus, the defendant's claim that she no longer has access to certain evidence is not a proper basis to dismiss the Indictment. See United States v. Donau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973) ("A bare allegation that records have been lost or destroyed, which might relate Ig The Government notes t
Entities connected to both Jane Doe and Donau

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Sarah Kellen
PERSONMartin Weinberg
PERSONFBI
ORGANIZATION
Ken Starr
PERSONthe Eleventh Circuit
ORGANIZATION
Julie K. Brown
PERSON
Southern District of New York
ORGANIZATION