Epstein Secrets

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

t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney

er of "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In Ruiz, the defendant was a New York state senator who founde

, 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

t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney

r o f "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In Ruiz, the defendant was a New York state senator who founde

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

t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney

er of "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In Ruiz, the defendant was a New York state senator who founde

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

t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney

er of "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In Ruiz, the defendant was a New York state senator who founde

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

t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney

er of "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In 142 EFTA00095234 Ruiz, the defendant was a New York stat

upposedly took place (1994-1997). The plaintiff in the defamation action, made wild and false accusations that she had been sexually trafficked by Epstein and Ms. Maxwell to dozens of famous politicians, professors, foreign leaders, and others. When Ms. Maxwell denied these allegations as false, sued

OF THE ALLEGATIONS A. Counts One through Four (the "Mann Act Counts") Counts One and Three of the Indictment allege that Ms. Maxwell conspired with Jeffrey Epstein and "others known and unknown" to violate two separate provisions of the Mann Act. Count One alleges that Ms. Maxwell conspired with Epstein to enti

OUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ted to and appropriately joined with underlying 7 EFTA00091885 substantive crimes when the false declarations "concern the substantive offenses." Potamitis, 739 F.2d at 791. Such cases typically involve situations where the defendant was aware that he was being investigated and either lied to the grand

e statements underlying the Perjury Counts therefore do not "concern" the Mann Act Counts and cannot be joined as part of a "common scheme or plan." Potamitis, 739 F.2d at 791. The government makes only a half-hearted, and ineffective, attempt to allege a connection between the Perjury Counts and the Man

The Perjury Counts allegedly occurred 22 years after the Mann Act Counts, during a defamation action concerning not whether Accuser-1 had sex with Jeffrey Epstein or Accusers-2 or 3 got a "massage," but whether the fantastical statements made by in 2015 were "obvious lies." Those wild, now known to be false,

cked to famous people and her purported four years as a sex slave. None of the Accusers in the Indictment claim to have been sexually trafficked by Epstein or Ms. Maxwell to anyone, let alone any famous people. And the defamation case had nothing to do with any allegations by Ms. of being enticed to t

OUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

dly made a materially false statement that relates directly to the underlying crime and the crime is temporally related to the false statement. The Potamitis case that the government relies upon primarily for this proposition is a good example. In that case, the defendant was charged with making false st

ion of justice because he lied to the FBI agents and the Grand Jury about the underlying crimes for which he was being investigated and questioned. Potamitis, 739 F.2d at 786-87; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (common plan or scheme between lying on a non- profit's loan applic

The Perjury Counts allegedly occurred 22 years after the Mann Act Counts, during a defamation action concerning not whether Accuser-1 had sex with Jeffrey Epstein or Accusers-2 or 3 got a "massage," but whether the fantastical statements made by in 2015 were "obvious lies." Those wild, now known to be false,

cked to famous people and her purported four years as a sex slave. None of the Accusers in the Indictment claim to have been sexually trafficked by Epstein or Ms. Maxwell to anyone, let alone any famous people. And the defamation case had nothing to do with any allegations by Ms. of being enticed to t

OUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

dly made a materially false statement that relates directly to the underlying crime and the crime is temporally related to the false statement. The Potamitis case that the government relies upon primarily for this proposition is a good example. In that case, the defendant was charged with making false st

ion of justice because he lied to the FBI agents and the Grand Jury about the underlying crimes for which he was being investigated and questioned. Potamitis, 739 F.2d at 786-87; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (common plan or scheme between lying on a non- profit's loan applic