3
Shared Docs
1
Same-Page
6 / 3
Mentions
e defendant's participation in conspiracies to transport and entice minor girls to travel with the intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant's attempt to cover up that conduct during her civil deposition testimony in 2016. Specifically, the Indict
akes plain that the defendant is charged with engaging in a conspiracy to transport minor girls with intent that they engage in sexual activity with Epstein, engaging in a conspiracy to entice minor girls to travel with the intent that they engage in sexual activity with Epstein, aiding and abetting the
otion should accordingly be denied as moot. 65 In articular, fin page 12 of the notes from this 2006 intery line indicates tha s l , mor is that JE is gay," apparently referring to e Epstein's sexual orien ation. pt Out of an abundance of caution. today the Government has informed defense coun
intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant
ent's proof to particulars furnished," it can "restrict unduly the Government's ability to present its case." Henry, 861 F. Supp. at 1197; see also Mitlof, 2014 WL 4243657, at *2 (recognizing that "care must be taken" because "[t]he government's presentation of evidence at trial is limited to the part
Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon Mor an and Foreman, P.C.
Page: EFTA00023910 →mation with respect to where, when, and with whom the Government will charge the defendant with conspiring are routinely denied."); United States v. Mitlof, 165 F. Supp. 2d 558, 569 (S.D.N.Y. 2001) ("What defendant seeks is in the nature of the `wheres, whens and with whoms' that [c]ourts have held to
Page: EFTA00023912 →Esq. ohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon Mor an and Foreman, P.C.
Page: EFTA00030943 →mation with respect to where, when, and with whom the Government will charge the defendant with conspiring are routinely denied."); United States v. Mitlof, 165 F. Supp. 2d 558, 569 (S.D.N.Y. 2001) ("What defendant seeks is in the nature of the `wheres, whens and with whoms' that [c]ourts have held to
Page: EFTA00030945 →Entities connected to both Jeffrey Epstein and Mitlof

Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Audrey Strauss
PERSONJeffrey Pagliuca
PERSONLaura Menninger
PERSONSecond Circuit
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATION
Christian Everdell
PERSONBobbi C. Sternheim
PERSONMark Cohen
PERSON
Giglio
PERSON
Torres
PERSONGibson
PERSONWalsh
PERSON
Castro
PERSON
Jencks
PERSONBortnovsky
PERSONMandell
PERSONDupigny
PERSON