Epstein Secrets

epositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 (hereinafter, "Petitioners"), at his mansion in Palm Beac

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

er, "DE 407" at 1 1.) Because EFTA00010507 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

epositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 ( hereinafter, "Petitioners"), at his mansion in Palm Bea

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

er, "DE 407" at 9 1.) Because EFTA00027666 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

ents, and world leaders are highly relevant and admissible (Motion in Limine 1) ..00...0.. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 FOIA responses and related materials are admissible (Motion in Limine 3).................. 8 io)

er intervening causes of emotional distress and related damages (Motion in Limine 14) 23 15. Plaintiff's lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15)... cccccccccccssenseecseeessecssecsecsseesseeeseecssessecsesteesteeens 24 16. All of Plaintiff’s m

aintiff's lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15

ian River Estates, Inc., 276 F.3d 790, 799 n.5 (6th Cir. 2002) . 13 Rowe v. DPI Specialty Foods, Inc., No. 2:13-CV-00708-DN, 2015 WL 3533844, at *5 (D. Utah i eb) 13,28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N.Y. 2009) oo. cccccteeeseeeee 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-

le a response, including (if necessary) proposing further remedies. Further cross-briefing could follow, assuring all parties (including intervenor Jeffrey Epstein) a chance to place their views before the Court. This approach would place the Court in a position to rule expeditiously. While the Government oppo

ollow, assuring all parties (including intervenor Jeffrey Epstein) a chance to place their views before th

ecade, during which the Government repeatedly created obstacles to reaching the merits of whether CVRA violations occurred when the Government (and Epstein) purposely concealed the consummation and execution of a secret non-prosecution agreement (NPA). On February 21, 2019, this Court brought the initia

e of communication between prosecutors and victims that was intended by the passage of the CVRA. See United States v. Heaton, 458 F. Supp. 2d 1271 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to engage in unlawful sexual activity would no

orable Richard M. Berman United States District Court Southern District of New York United States Courthouse July 12, 2019 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Rel

chard M. Berman United States District Court Southern District of New York United States Courthouse July 12, 2019 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (t

Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Utah Aug. 27, 2013); United States v. Cohen, No. C 10-00547, 2010 WL 5387757, at *9 n. I I (N.D. Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp.