Epstein Secrets

tness an individual ("Employee-1") who worked for Jeffrey Epstein immediately 35 EFTA00088837 followin

osed testimony concerns the experience of manipulated and coerced victims, rather than the intentions of perpetrators. 19 EFTA00088821 return to Epstein's home for sexual abuse, or why some occasionally expressed affection for the defendant and Epstein. Although Dr. will not testify about these spe

consideration of the Court's pretrial order denying the defense's motion to strike Minor Victim-3 from the Indictment. Evidence of the defendant and Jeffrey Epstein's abuse of Minor Victim-3 is direct evidence of the offense charged in the Indictment, including the overt acts in the Indictment that pertain to Mino

elationship between the defendant and Epstein. For instance, to the extent the defense at trial argues that the defendant was merely an employee of Epstein's, this photograph is evidence to the contrary. Sixth, the defense argues that Government Exhibit 606 lacks evidentiary foundation, is hearsay, and i

st this weight of authority, the defendant relies principally on one case from the District of Maine. United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). The proposed 13 EFTA00088815 testimony in this case is readily distinguishable from that in Raymond. There, the government gave notice o

S DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA GRAND JURY MATTER FILED UNDER SEAL IN RE GRAND JURY SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND INCORPORATED MEMORANDUM OF LAW Now comes Jeffrey Epstein and respectfully moves this Honorable

Mr. Jeffrey Epstein, including, but not ling to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; ••••••r telephone logs or records

Y SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUB

illing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records

ts irrelevant to the grand jury inquiry and was, therefore, unreasonably broad under Rule 17. Likewise, in In re Amato, 2005 WL 1429743 at *11-*12 (D. Me. June 17, 2005), the Court, relying on a number of cases dealing with searches of computers pursuant to warrants, granted a motion to quash with re

eement of the parties. that appearance was rescheduled for July 17, 2007. The day before that scheduled appearance, i.e.. July 16. 2007. counsel for Jeffrey Epstein, who seeks to intervene in this matter, was informed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motio

nformed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motion to quash the subpoena at issue was filed by Epstein before the end of the day on July 17. 2007. As the Government's Response states. Epstein's motion to quash was filed on July 17, 2007 before the clo

he Response of the United States to the Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub

d jury subpoenas to investigator and his firm, Mr. Epstein is represented by undersigned counsel Roy Black.

ts irrelevant to the grand jury inquiry and was, therefore, unreasonably broad under Rule 17. Likewise, in In re Amato, 2005 WL 1429743 at *11-*12 (D. Me. June 17, 2005), the Court, relying on a number of cases dealing with searches of computers pursuant to warrants, granted a motion to quash with re

l activity without physical force. These opinions may also assist a jury in assessing evidence that some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered abuse. Dr. Rocchio's fourth opinion is similarly relevant to the charges that require proving inten

leged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered

some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they s

probative value. These arguments rely heavily on a district court opinion from outside this circuit, United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). After careful consideration of the Defense's arguments and the thorough reasoning in Raymond, the Court concludes that Dr. Rocchio's antici

tends represent "direct evidence" of a conspiracy (to recruit, groom, and sexually abuse minor females or to entice, transport or traffic them for Jeffrey Epstein's sexual pleasure) that Resp. at 36. 2 The proffered evidence is found at GX 401-404, 409-410 and 413 7 EFTA00090733 The government contends that

government clearly intends to rely on how open the alleged abuse was, the relevance of evidence that even the people who claim they were abused by Epstein during the same time frame but without any knowledge or participation by Ms. Maxwell becomes highly relevant to rebut such testimony. 12 EFTA00090

ELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN &

(S.D.N.Y. 2020) 37 United States v. Golyansky, 291 F.3d 1245 (10th Cir. 2002) 4 United States v. Gonyer, No. 1:12-CR-00021-JAW, 2012 WL 3043020 (D. Me. July 24, 2012)20 United States v. Graham, No. 14 Cr. 500 (NSR), 2015 WL 6161292 (S.D.N.Y. Oct. 20, 2015) 38 United States v. United States v. Un

l activity without physical force. These opinions may also assist a jury in assessing evidence that some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered abuse. Dr. Rocchio's fourth opinion is similarly relevant to the charges that require proving inten

leged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered

some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they s

probative value. These arguments rely heavily on a district court opinion from outside this circuit, United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). After careful consideration of the Defense's arguments and the thorough reasoning in Raymond, the Court concludes that Dr. Rocchio's antici

l activity without physical force. These opinions may also assist a jury in assessing evidence that some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered abuse. Dr. Rocchio's fourth opinion is similarly relevant to the charges that require proving inten

leged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered

some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they s

probative value. These arguments rely heavily on a district court opinion from outside this circuit, United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). After careful consideration of the Defense's arguments and the thorough reasoning in Raymond, the Court concludes that Dr. Rocchio's antici