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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
determining whether an indictment is in fact multiplicitous," and the record cannot be fully established until trial is complete. United States v. McCouny, 562 F.3d 458, 469 (2d Cir. 2009). Additionally, because double jeopardy is meant to protect a defendant from successive punishments for the same of
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
determining whether an indictment is in fact multiplicitous," and the record cannot be fully established until trial is complete. United States v. McCouny, 562 F.3d 458, 469 (2d Cir. 2009). Additionally, because double jeopardy is meant to protect a defendant from successive punishments for the same of
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
determining whether an indictment is in fact multiplicitous," and the record cannot be fully established until trial is complete. United States v. McCouny, 562 F.3d 458, 469 (2d Cir. 2009). Additionally, because double jeopardy is meant to protect a defendant from successive punishments for the same of
Entities connected to both Jeffrey Epstein and McCouny

Ghislaine Maxwell
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSONJane Doe
PERSONMaria Farmer
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Bill Richardson
PERSON
Palm Beach
LOCATION
Scarlett Johansson
PERSONDoug Band
PERSON
Michael Jackson
PERSON
David Boies
PERSON
Milan
LOCATION
Colorado
LOCATION
Southern District of New York
ORGANIZATION