Epstein Secrets

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

Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied 185 XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper 193 A. Background 194 1. The SDNY and Local Rules for the Division of Business 194 2. The SDNY Any Plan 19

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

eks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XL The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29,2020, amidst a global pandemic that suspendedgrand juries across the country, the Government sought

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

ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough

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

ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough

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

ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough

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

ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough