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Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2
rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than , and therefore that her answer was false. And even if the d
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant testified t
sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? A. No. not that I recall. q
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question for post hoc ambiguity," Strohm, 671 F.3d at 1178. A reasonable
, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-SDNY to "open an investigation of the duo" during that meeting. Citing two anonymous sources, the Article described th
rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than and therefore that her answer was false. And even if the def
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). 'ounsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant testified t
, the following colloquy occurred: When you and Mr. Epstein were engaged in sexual activity that included th
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question forpost hoc ambiguity,"Strohm, 671 F.3d at 1178. A reasonable j
Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2
rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than Giuffre, and therefore that her answer was false. And even i
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te
e following colloquy occurred: Er. When you and Mr. Epstein were engaged in sexual activity that included th
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question for post hoc ambiguity," Strohm, 671 F.3d at 1178. A reasonable
Order On or about April 9, 2019, the Government advised Judge Netbum, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et at, 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. I). Subsequently, on April 16, 2
rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than Giuffre, and therefore that her answer was false. And even i
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te
e following colloquy occurred: Er. When you and Mr. Epstein were engaged in sexual activity that included th
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question for post hoc ambiguity," Strohm, 671 F.3d at 1178. A reasonable
2016 meeting (the "Daily News Article" or the "Article") .36 The Article stated, among other things, that defense attorneys representing victims of Epstein and the defendant "urged" the USAO-SDNY to "open an investigation of the duo" during that meeting. Citing two anonymous sources, the Article descri
underage girls that the defendant met and brought to Epstein. Specifically: Q. Can you list for me all the girls that you have met and brought to Jeffrey Epstein's house that were under the age of 18? MR. PAGLIUCA: Objection to the form and foundation. A. I could only recall my family members that were there a
out whether the defendant brought women to Epstein, which the defendant resisted by observing that she hired "people across the board" to "work for Jeffrey." (Id. at 245:7-18). Giuffre's counsel asked whether any minors worked as exercise instructors or masseuses at Epstein's home, and the defendant te
Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question for post hoc ambiguity," Strohm, 671 F.3d at 1178. A reasonable
m three colloquies at the second deposition. act at 5 de Following that line of questioning, the following colloquy occurred: When you and Mr. Epstein were engaged in sexual activity that included these other women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were
Page: EFTA00029847 →, the following colloquy occurred: When you and Mr. Epstein were engaged in sexual activity that included th
Page: EFTA00029847 →nt's professed confusion now and proposed illogical reading of the questions in the instant motion does not render them fundamentally ambiguous. See Bonacorsa, 528 F.2d at 1221 ("A defense to a charge of perjury may not be established by isolating a statement from context, giving it in this manner a meani
Page: EFTA00029851 →Entities connected to both Jeffrey Epstein and Bonacorsa

Ghislaine Maxwell
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSONJane Doe
PERSONMaria Farmer
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Bill Richardson
PERSON
Palm Beach
LOCATION
Scarlett Johansson
PERSONDoug Band
PERSON
Michael Jackson
PERSON
David Boies
PERSON
Milan
LOCATION
Colorado
LOCATION
Southern District of New York
ORGANIZATION