Epstein Secrets

me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.i ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00102999 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

e, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623. 1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00099941 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case. 3 A. The NPA Does Not Bind the Southern District of New Yolk 4 1. The Text of the Agreement

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197,199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Borti, No. 08 Cr. 2

she has produced nothing. 65 In articular, bei r e' eroluren-otesTrorrithis 20O5-mTervrevonntitri mor is that JE is gay," an apparent reference to Jeffrey Epstein's rumored sexual 185 EFTA00100152 in . Accordingly, the records of these interviews constitute witness statements covered by the Jencks Act and a

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 178 EFTA00100145 minor girls to travel with the intent that they engage in sexual activity with Epstein, aidi

ery from the defendant and, to date, she has produced nothing. 65 In articular, bei r e' eroluren-otesTrorrithis 20O5-mTervrevonntitri mor is that JE is gay," an apparent reference to Jeffrey Epstein's rumored sexual 185 EFTA00100152 in . Accordingly, the records of these interviews constitut

intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("`[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00100146 Particulars are nec

me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00077606 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant

produced nothing. 65 In articular, Mr/Wf2 of the notes from this 206glinMew, a single line ted, "rumor is that JE is gay," an apparent reference to Jeffrey Epstein's rumored sexual 185 EFTA00077817 in made by ss "M" in 2006. Accordingly, the records of these interviews constitute witness statements covered b

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 178 EFTA00077810 minor girls to travel with the intent that they engage in sexual activity with Epstein, aidi

the defendant and, to date, she has produced nothing. 65 In articular, Mr/Wf2 of the notes from this 206glinMew, a single line ted, "rumor is that JE is gay," an apparent reference to Jeffrey Epstein's rumored sexual 185 EFTA00077817 in made by ss "M" in 2006. Accordingly, the records of thes

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("c[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00077811 Particulars are nec

me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant

produced nothing. 65 In articular, Mr/Wf2 of the notes from this 206glinMew, a single line ted, "rumor is that JE is gay," an apparent reference to Jeffrey Epstein's rumored sexual 185 EFTA00039632 in made by ss "M" in 2006. Accordingly, the records of these interviews constitute witness statements covered b

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 178 EFTA00039625 minor girls to travel with the intent that they engage in sexual activity with Epstein, aidi

the defendant and, to date, she has produced nothing. 65 In articular, Mr/Wf2 of the notes from this 206glinMew, a single line ted, "rumor is that JE is gay," an apparent reference to Jeffrey Epstein's rumored sexual 185 EFTA00039632 in made by ss "M" in 2006. Accordingly, the records of thes

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("c[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00039626 Particulars are nec

me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"

illegal sex acts, and aiding and abetting the same, in violation of 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti

NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant

f America Assistant United States Attorneys - Of Counsel - EFTA00095067 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 174 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 120, 127, 133, 135 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 179 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 174, 175, 182 United States v. Botti, No. 08 Cr. 2

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

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) (m[E]videntiary detail is not the function of the bill of particulars.' Particulars are necessary only where ind

intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant

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 178 EFTA00103203 minor girls to travel with the intent that they engage in sexual activity with Epstein, aidi

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("1E]videntiaty detail is not the function of the bill of particulars.' 179 EFTA00103204 Particulars are nece