Epstein Secrets

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three

"necessary to complete the story of the crime on trial." United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012) ("Robinson argued at trial that Jane Doe was his `girlfriend' and that he had no control over her prostitution activities. Evidence that Robinson was in the prostitution business and contro

ich evidence of prior crimes, wrongs, or acts is admissible for any purpose other than to show a defendant's criminal propensity." United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006) (internal quotation marks omitted). Where the defendant claims her conduct has an innocent explanation, the admiss

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three

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

ited States v. Page, 657 F.3d 126 (2d Cir. 2011) 205, 209, 210, 220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.

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

ited States v. Page, 657 F.3d 126 (2d Cir. 2011) 205, 209, 210, 220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.

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,

United States v. Page, 657 F.3d 126 (2d Cir. 2011) 138, 140, 147 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 165 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 165 United States v. Payner, 447 U.S. 727 (1980) 82, 110 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.Y. 201

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

relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, 165 EFTA00095257 uncharged

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,

relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, uncharged acts are admissible