Epstein Secrets

nd, et al., Modern Federal Jury Instructions, Instr. 64-16; the charge of the Hon. Richard J. Arcara in United States v. Vickers, 13 Cr. 128 (RJA) (W.D.N.Y.), aff'd, 708 F. App'x 732 (2d Cir. 2017); and the charge of the Hon. Thomas P. Greisa in United States v. Gilliam, 11 Cr. 1083 (TPG), ard, 842 F.3d

nise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC); and the charge of the Hon. Ann M. Donnelly in United States v. Kelly, 19 Cr. 286 (AMD) (E.D.N.Y.). See United States v. Murphy, 942 F.3d 73, 79-84 (2d Cir. 2019) (holding under 18 U.S.C. § 2423(b) that a defendant must know the age of the vict

ellow jurors, and if you apply your own common sense, you will deliberate fairly. Dated: New York, New York October 2021 Respectfully submitted, DAMIAN WILLIAMS [Defense signature block] United States Attorney By: Assistant United States Attorneys 86 EFTA00074589

that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yesterday's testimony that the witness used first names of certain

wn to you during jury selection. This process should not bear in any way on your evaluation of the evidence in this case. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By email) EFTA00102348 C

reating, and speaking to prostitutes was sufficiently reliable. Id. at 263- 64; see also, e.g., Letter, United States v. Kelly, No. 19 Cr. 286 (AMD) (E.D.N.Y. July 23, 2021) (Dkt. No. 134); United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at •6 (S.D.N.Y. May 13, 2021) (permitting expert tes

MERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys

that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yesterday's testimony that the witness used first names of certain

wn to you during jury selection. This process should not bear in any way on your evaluation of the evidence in this case. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By email) EFTA00099093 C