Epstein Secrets

8's eighteenth birthday, and when Jane Doe #19 was seventeen years old. [NB: The police report describes a pattern of activity, including dates when Jane Doe #18 was seventeen years old.] Neither Jane Doe #18 nor #19 ever returned to Epstein's home. Although we have not yet obtained Jane Doe #18's teleph

ent status from presumed innocence and release on bail prior thereto. The statute recognizes the different status. The defendant in United States' Zannino, 761 F.2d 52 (1st Cir.1985), was admitted C 2008 Thomson/West. No Claim to Orig. U.S. Govt. Works. https://web2.westlaw.com/print/printstream.aspx

n under the prior Bail Reform Act of 1966, bail terms were "subject to review when changed circumstances require that the release be reappraised." Zannino, supra, at 55. The Court cited 18 U.S.C. § 3146(e), repealed by18 U.S.C. § 3142(c), which reads in part: A judicial officer ordering the release

ied female in the presence of Jane Doe #2, who was then a fourteen- year-old girl. 17 (8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. (9) On or

px?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008 EFTA00191689 Page 1 of 10 w estlaw 761 F.2d 52 761 F.2d 52 (Cite as: 761 F.2d 52) H U.S. II. Zannino C.A. (Mass.),1985. United States Court of Appeals,First Cir- cuit. UNITED STATES of America, Plaintiff, Appellant, v. Ilario M.A. ZANNINO, Defe

nd six others. The charges related to murders, gambling, and other illegal acts. When first brought be- fore the magistrate on September 20, 1983, Zannino was ordered held without bail on the grounds that no conditions of pretrial release would reasonably assure his ap- pearance at trial. Eventually,

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

government has neither argued for a narrow waiver nor identified any particular document to which such a waive! might extend. See United States . Zannino, 895 F.2d 1, 17 (1st Cir. 990) (explaining that arguments not made in • a party's bnefs need not be considered). 120] Viewed against this backdro