Epstein Secrets

e 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 DISCOVERABLE UNDER RULE 501 Jane Doc 1 and Jane Doe 2 are also not entitled to discovery or use of the p

entity of the interviewing agents and the nature of the interview, WILD provided the following information: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with personal massages. WILD was approached at a party by a female she believoi was named CHARLISE. She described

onths, one week and 3 days. EFTA00178032 FD-302a (Rev. 10-6-95) 31E-MM-108062 Continuation of FD-302 of Shawna Lane Rivera .On 05/28/2008 ,Page Epstein offered to pay an extra $100.00 to Rivera if she brought additional girls to him. Epstein asked Rivera to provide a massage to Sarah LNU but the ma

ormation: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with pe

e plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

to exist. With isthmian exceptions not pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality. See 8 Wigmore, supra § 2311, at 601-03 & nn. 6-8 (collecting cases). So here: XYZ knew that third parties-representatives of Smallco- were participating in the

ill preclude the expert testimony of Dr. Ryan Hall The Government moves to preclude the expert testimony of Dr. Ryan Hall. Dr. Hall was retained by Jeffrey Epstein to evaluate Alleged Victim 4, which Dr. Hall did in 2009, in connection with Alleged Victim 4's civil suit against Epstein. Epstein admitted liabili

was retained by Jeffrey Epstein to evaluate Alleged Victim 4, which Dr. Hall did in 2009, in connection with Alleged Victim 4's civil suit against Epstein. Epstein admitted liability for sexually abusing Alleged Victim 4 and the dispute was about the extent of damages only. Dr. Hall issued a report in

imony of Dr. Ryan Hall. Dr. Hall was retained by Jeffrey Epstein to evaluate Alleged Victim 4, which Dr. H

s under the influence of drugs or narcotics or alcohol at the time of observation of events in dispute or at the time the witness is testifying. As Wigmore points out, however, a general habit of intemperance tells us nothing of the witness's testimonial incapacity unless it involves actual intoxication

ill preclude the expert testimony of Dr. Ryan Hall The Government moves to preclude the expert testimony of Dr. Ryan Hall. Dr. Hall was retained by Jeffrey Epstein to evaluate Alleged Victim 4, which Dr. Hall did in 2009, in connection with Alleged Victim 4's civil suit against Epstein. Epstein admitted liabili

was retained by Jeffrey Epstein to evaluate Alleged Victim 4, which Dr. Hall did in 2009, in connection with Alleged Victim 4's civil suit against Epstein. Epstein admitted liability for sexually abusing Alleged Victim 4 and the dispute was about the extent of damages only. Dr. Hall issued a report in

imony of Dr. Ryan Hall. Dr. Hall was retained by Jeffrey Epstein to evaluate Alleged Victim 4, which Dr. H

s under the influence of drugs or narcotics or alcohol at the time of observation of events in dispute or at the time the witness is testifying. As Wigmore points out, however, a general habit of intemperance tells us nothing of the witness's testimonial incapacity unless it involves actual intoxication

at the time of the events in question do not favor admission. Dr. Hall's report does not delineate clearly which conditions existed at the time of Epstein's abuse, but it appears that at least But at no point in his report does Dr. Hall suggest that these conditions—or any other diagnosed condition

s under the influence of drugs or narcotics or alcohol at the time of observation of events in dispute or at the time the witness is testifying. As Wigmore points out, however, a general habit of intemperance tells us nothing of the witness's testimonial incapacity unless it involves actual intoxication

ry to prove the certainty of their innocence. The Jeffrey MacDonald case discussed previously, is a prime e

ion that when it comes to rape only women always tell the truth. This bias is an wrongheaded as the anachronistic bias, reflected in the writings of Wigmore and others, that men are more likely to tell the truth than women. A highly publicized case in 2011 may well illustrate the reality that both men an