Epstein Secrets

.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SJF) (AYS), 2019 WL 3072288 (E.D.N.Y. July 15, 2019) 86 United States v. Dumitru, No. 18 Cr. 243 (LAK), 2018 WL 3407703 (S.D.N.Y. June 26, 2018) 261 United States v. Eldred, 933 F.3

bit 3: Exhibit 4: Exhibit 5: Exhibit 6: Exhibit 7: Exhibit 8: Exhibit 9: Exhibit 10: Exhibit 11: Exhibit 12: Notes from the U.S. Attorney's Office for the Southern District of New York June 14, 2007 Email November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Notes from February 11, 2021 Call Note

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. 1). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

0, 2018 Email December 6, 2018 Email Feb m deb Transcript of April 22, 2016 Deposition Transcript of July 22, 2016 Deposition Affidavit of Dr. Bernard R. Siskin iv EFTA00099945 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. ofPlayers Computer Inc. v. Sta

F. Supp. 2d 590 (S.D.N.Y. 2008) 151 United States v. Ash, 464 F. Supp. 3d 621 (S.D.N.Y. 2020) 145 United States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United Sta

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. I). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

dge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00077610 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. S

F. Supp. 2d 590 (S.D.N.Y. 2008) 151 United States v. Ash, 464 F. Supp. 3d 621 (S.D.N.Y. 2020) 145 United States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United Sta

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. I). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

dge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00039425 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. S

311 (E.D.N.Y. 2016) 7 United States v. Bunn, 154 F. App'x 227 (2d Cir. 2005) 237 United States v. Burke, No. 09 Cr. 135 (SJ), 2011 WL 2609837 (E.D.N.Y. July 1, 2011) 82 United States v. Butler, 351 F. Supp. 121 (S.D.N.Y. 2004) 243 United States v. Butler, No. 04 Cr. 340, 2004 WL 2274751 (S.D.N.

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. 1). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

udge Netbum Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00103003 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer; Inc. v. S

population and the group's representation in the relevant jury pool. See Rioux, 97 F.3d at 655; United States v. Barlow, 732 F. Supp. 2d 1, 30- 31 (E.D.N.Y. 2010), aff'd 479 F. App'x 372, 373 (2d Cir. 2012). For example, if Blacks represented 10% of the community population but only 2% of the relevant ju

o. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. Skiskin's report, geocoding is based on estimating the proportion of persons who a

population and the group's representation in the relevant jury pool. See Rioux, 97 F.3d at 655; United States v. Barlow, 732 F. Supp. 2d 1, 30- 31 (E.D.N.Y. 2010), gird 479 F. App'x 372, 373 (2d Cir. 2012). For example, if Blacks represented 10% of the community population but only 2% of the relevant jur

o. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. Skiskin's report, geocoding is based on estimating the proportion of persons who a

population and the group's representation in the relevant jury pool. See Rioux, 97 F.3d at 655; United States v. Barlow, 732 F. Supp. 2d 1, 30- 31 (E.D.N.Y. 2010), gird 479 F. App'x 372, 373 (2d Cir. 2012). For example, if Blacks represented 10% of the community population but only 2% of the relevant jur

o. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. Skiskin's report, geocoding is based on estimating the proportion of persons who a

population and the group's representation in the relevant jury pool. See Rioux, 97 F.3d at 655; United States v. Barlow, 732 F. Supp. 2d 1, 30- 31 (E.D.N.Y. 2010), gird 479 F. App'x 372, 373 (2d Cir. 2012). For example, if Blacks 70 The American Community Survey gathers demographic information in between

e, 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. Skiskin's report, geocoding is based on estimating the proportion of persons who a

population and the group's representation in the relevant jury pool. See Biota, 97 F.3d at 655; United States v. Barlow, 732 F. Supp. 2d 1, 30- 31 (E.D.N.Y. 2010), grid 479 F. App'x 372, 373 (2d Cir. 2012). For example, if Blacks represented 10% of the community population but only 2% of the relevant jur

o. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. Skiskin's report, geocoding is based on estimating the proportion of persons who a