Epstein Secrets

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

t understand why the Minor Victims continued to 3 In United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639 (E.D.N.Y. May 22, 2019), Judge Garaufis questioned whether an expert on grooming with experience focused on victims may have been able to testify reliably about how "perpetrators often use

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

formation. III. Limiting Instruction The Government requests 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 yes

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

formation. III. Limiting Instruction The Government requests 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 yes