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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 &
. SI 08 Cr. 404 (SCR), 2009 WL 10688209 (S.D.N.Y. Jul. 15, 2009) 26 United States v. D 'Amelio, 683 F.3d 412 (2d Cir. 2012) 14 United States v. Dupre, 462 F.3d 131 (2d Cir. 2006) 14 United States v. Ehrens, No. CR-15-200-C, 2015 WL 7758544 (W.D. Okla. Dec. 1, 2015) 39 iii EFTA00090724 United
s being conducted at the 19 This is an official DOJ/OIG investigation into 20 Metropolitan Correctional Center, or the MCC, 20 the death of inmate Jeffrey Epstein, and the 21 located in New York, New York. Also present is 21 surrounding circumstances, and you are being 22 DOJ/OIG Special Agent . This 22 ask
Basically, like, a very knowled eable correctional officer? : Yes. Yes. About that. Yeah. Okay. Did you have any interactions or involvement with Epstein during his stay at MCC? No. No. Did you even communicate with him at all? No. : Did you see him at all? : I seen him once. I think he was dow
ional Center, or the MCC, 20 the death of inmate Jeffrey Epstein, and the 21 located in New York, New Yor
't remember. : Sure. : And then -- : It's been a while. -- on August 10th, 2019, it says you were internal two, internal one was - does that say Dupre? : Yeah. He don't come in -. Oh, well. He's internal. So, that's the person that I'm hel in to conduct the count with. : Okay. So, he is doing a
3 Deutsche Asset & Wealth Management Detailed Portfolio Information .0'6,635.15 Li. of Makings • Cash and Cash Equivalents Cs. Account Name. JEFFREY EPSTEIN Account Number. 680519 Base Currency: 1.150 Duaertity Security (346cript. %al teal us Cam Pea in U. Adjust. Cast W.% Val. Mtn. Due. ht...
and Cash Equivalents Cs. Account Name. JEFFREY EPSTEIN Account Number. 680519 Base Currency: 1.150
• Cash and Cash Equivalents Cs. Account Name. JEFFREY EPSTEIN Account Number. 680519 Base Currency:
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Entities connected to both Jeffrey Epstein and Dupre