Epstein Secrets

80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. _____________ / 0 DEFENDANT EPSTE

ocket 05/06/2010 Page 2 of 31 Jane Doe No. 2 v. Epstein Case No. 08-CV-80119-Marra-Johnson Page 2 in m

f Count III, Plaintiff "demands judgment against Jeffery Epstein for all damages available under 18 U.S.C. §2255(a

JEFFREY EPSTEIN, Defendant. _____________ / 0 DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORT

8691 [email protected] Counsel for Defendant Jeffrey Epstein Case 9:08-cv-80119-KAM Document 539

se, or attempting to do so. See for e.g., U.S. v. Gagliardi, 506 F.3d 140, 150-51 (2d Cir. 2007). In Gagliar

vision The United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, Florida 33132 Dear• Mr. Menthe': July 25, 2007 Jeffiry Epstein TELEPHONE la 1E)7370400 m ailman We have previously provided you with a memo as to why we believe no charge under 18 U.S.C. §2422(b) could or sho

ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's ease.' Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the

.S.C. §2422(b) could or should be brought against Jeffrey Epstein, even assuming the specific conduct that

beyond recognition to fit the particular facts of Mr. Epstein's ease.' Enclosed is data that strongly supports

gs were removed but new expert required because he saw exemplars containing the spelling errors. 2422(b); 1470 (mail) Not Consummated U.S. v. Gagliardi, 2006 U.S. Dist. LEXIS 64576 (S.D.N.Y. 2006) Internet Private citizen pretended to be "13 yr- old"; defendant contacted and initiated sexually

tness an individual ("Employee-1") who worked for Jeffrey Epstein immediately 35 EFTA00088837 followin

osed testimony concerns the experience of manipulated and coerced victims, rather than the intentions of perpetrators. 19 EFTA00088821 return to Epstein's home for sexual abuse, or why some occasionally expressed affection for the defendant and Epstein. Although Dr. will not testify about these spe

consideration of the Court's pretrial order denying the defense's motion to strike Minor Victim-3 from the Indictment. Evidence of the defendant and Jeffrey Epstein's abuse of Minor Victim-3 is direct evidence of the offense charged in the Indictment, including the overt acts in the Indictment that pertain to Mino

elationship between the defendant and Epstein. For instance, to the extent the defense at trial argues that the defendant was merely an employee of Epstein's, this photograph is evidence to the contrary. Sixth, the defense argues that Government Exhibit 606 lacks evidentiary foundation, is hearsay, and i

on of evidence is not particularly high." United States v. El Gamma!, 831 F. App'x 539, 542 (2d Cir. 2020) (summary order) (quoting United States v. Gagliardi, 506 F.3d 140, 151 (2d Cir. 2007)). Rule 901 is "satisfied if sufficient proof has been introduced so that a reasonable juror could find in favor o

thern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: December 9, 2008 VIA UNITED STATES MAIL Re: Jeffrey Epstein : Notification of Work Release Dear Ms. Gagliardi: By virtue of this letter, the United States Attorney's Office hereby provides you with notice t

in has applied to participate in the Palm Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day,

e: December 9, 2008 VIA UNITED STATES MAIL Re: Jeffrey Epstein : Notification of Work Release Dear Ms.

, West Palm Beach, FL 33401. After work each day, Mr. Epstein returns to the Palm Beach County Stockade. While

e 400 West Palm Beach, FL 33401 Facsimile: December 9, 2008 VIA UNITED STATES MAIL Re: Jeffrey Epstein : Notification of Work Release Dear Ms. Gagliardi: By virtue of this letter, the United States Attorney's Office hereby provides you with notice that the U.S. Attorney's Office has learned that Jef

RENA FAITH BY HAND of of the Criminal Division The United States Attorney's Office Southern Distri of Florida tams, on a 3132 July 25, 2007 Jeffrey Epstein •ELE.T., FACSIMILE Dear Mr. We have previously provided you with a memo as to why we believe no charge under 18 U.S.C. §2422(b) could or should b

ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's case! Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the s

istri of Florida tams, on a 3132 July 25, 2007 Jeffrey Epstein •ELE.T., FACSIMILE Dear Mr. We have pr

beyond recognition to fit the particular facts of Mr. Epstein's case! Enclosed is data that strongly supports

s were removed but new expert required because lie saw exemplars containing the spelling errors. 2422(b); 1470 (mail) Not Consummated U.S. v. Gagliardi, 2006 U.S. Dist. LEXIS 64576 (S.D.N.Y. 2006) Internet Private citizen pretended to be "13 yr- old"; defendant contacted and initiated sexually

icate Government Exhibit 52 because - a former employee, purportedly removed the document from the property before Employee-1 began working for Mr. Epstein." (Id.) The Second Circuit has "often commented that the bar for authentication of evidence is not particularly high." United States v. Al-Moyad, 5

the property before Employee-1 began working for Mr. Epstein." (Id.) The Second Circuit has "often commented

mal.' The testimony of a witness with knowledge that a matter is what it is claimed to be is sufficient to satisfy this standard." United States v. Gagliardi, 506 F.3d 140, 151 (2d Cir. 2007) (citations and internal quotation marks omitted). After this low bar is satisfied, "the other party then remains f