Epstein Secrets

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

as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo

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

as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo

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

as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo

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

as well as the appropriate method of statistical comparison. See RiOUX, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo

on of this District could appear for grand jury service, the government, in its apparent determination to mark the anniversary of its indictment of Jeffrey Epstein with a July 2, 2020 announcement of the indictment and arrest of Ghislaine Maxwell, sought and obtained an indictment of Ms. Maxwell through a gran

cies occurred in the White Plains Division. To the contrary, the only specific location within this District that is referenced in the indictment is Epstein's residence on the Upper East Side of Manhattan, the location at which Ms. Maxwell allegedly intended for Minor Victim-1 to engage in unlawful sexu

Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the

on of this District could appear for grand jury service, the government, in its apparent determination to mark the anniversary of its indictment of Jeffrey Epstein with a July 2, 2020 announcement of the indictment and arrest of Ghislaine Maxwell, sought and obtained an indictment of Ms. Maxwell through a gran

cies occurred in the White Plains Division. To the contrary, the only specific location within this District that is referenced in the indictment is Epstein's residence on the Upper East Side of Manhattan, the location at which Ms. Maxwell allegedly intended for Minor Victim-1 to engage in unlawful sexu

LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the

on of this District could appear for grand jury service, the government, in its apparent determination to mark the anniversary of its indictment of Jeffrey Epstein with a July 2, 2020 announcement of the indictment and arrest of Ghislaine Maxwell, sought and obtained an indictment of Ms. Maxwell through a gran

cies occurred in the White Plains Division. To the contrary, the only specific location within this District that is referenced in the indictment is Epstein's residence on the Upper East Side of Manhattan, the location at which Ms. Maxwell allegedly intended for Minor Victim-1 to engage in unlawful sexu

LLP 800 Third Avenue New York NY 10022 Phone Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ivision and the qualified wheel for White Plains. Mr. Martin's analysis found significant underrepresentation of both Black and Hispanic persons in the White Plains qualified wheel when compared to the eligible juror population of the Manhattan Division. Mr. Martin found that the eligible juror population of the

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

as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo