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

.S. 702 (1997) Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118

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

U.S. 702 (1997) Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017). Zafiro v. United States, 506 U.S. 534 (1993) 151 passim 209,210,220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §1623(a) 118

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

698 F.2d 981, 984 (9th Cir. 1983) (finding that "[a] petit jury may be drawn constitutionally from only one division and not the whole district"); Zicarelli v. Dietz, 633 F.2d 312, 318 (3d Cir. 1980) ("[T]there is no constitutional right to a jury chosen from the division where the offense was committed

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

.S. 702 (1997) Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118

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

698 F.2d 981, 984 (9th Cir. 1983) (finding that "[a] petit jury may be drawn constitutionally from only one division and not the whole district"); Zicarelli v. Dietz, 633 F.2d 312, 318 (3d Cir. 1980) ("[T]there is no constitutional right to a jury chosen from the division where the offense was committed

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

.S. 702 (1997) Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118

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

698 F.2d 981, 984 (9th Cir. 1983) (finding that "[a] petit jury may be drawn constitutionally from only one division and not the whole district"); Zicarelli v. Dietz, 633 F.2d 312, 318 (3d Cir. 1980) ("[T]there is no constitutional right to a jury chosen from the division where the offense was committed

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

521 U.S. 702 (1997) 104 Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) passim Zafiro v. United States, 506 U.S. 534 (1993) 140, 147 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 201 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 85 Statutes 18 U.S.C. §1623(a) 119

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

292 F.2d 981, 984 (9th Cir. 1983) (finding that "[a] petit July may be drawn constitutionally from only one division and not the whole district"); Zicarelli v. Dietz, 633 F.2d 312, 318 (3d Cir. 1980) ("[Tjthere is no constitutional right to a jury chosen from the division where the offense was committed

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

698 F.2d 981, 984 (9th Cir. 1983) (finding that "[a] petit jury may be drawn constitutionally from only one division and not the whole district"); Zicarelli v. Dietz, 633 F.2d 312, 318 (3d Cir. 1980) ("[T)there is no constitutional right to a jury chosen from the division where the offense was committed