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

t understand why the Minor Victims continued to 3 In United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639 (E.D.N.Y. May 22, 2019), Judge Garaufis questioned whether an expert on grooming with experience focused on victims may have been able to testify reliably about how "perpetrators often use

te/florida/article247183924.html> (11/14, Wieder, Hall, 1.09M) reports, "A Justice Department look-back report into its abortive 2008 prosecution of Jeffrey Epstein found that the Federal Bureau of Investigation had planned to arrest Jeffrey Epstein in May 2007, but pulled back after the U.S. Attorney's Office f

y's Office for the Southern District of Florida, led by former Labor Secretary Alexander Acosta, frowned on the plan. The report also concludes that Epstein wasn't assisting the federal government in prosecuting Wall Street traders behind the collapse of investment bank Bear Stearns or serving as an "in

-abuse> Norfolk, VA (11/15, 163K) reports Bradley Jeffrey-Moe "was convicted Friday on charges of receivin

nited States as children because his appointment to the top position in the department did not appear to be lawful." In "an unusual Saturday ruling" Garaufis "said...that the `plain text' of the department's order of succession showed that Wolf's ascension to acting secretary did not follow established la

ration/dhs-secretary-unlawful- daca/2020/11/I 5/c52ae64e-26d1-11eb-8672-c281c7a2c96e_story.html> (11/15, Sacchetti, 14.2M) reports US District Judge Nicholas G. Garaufis of New York "has ruled that acting Homeland Security Secretary Chad Wolf lacked the authority to limit the work permits of hundreds of thousands of

fore Plea Deal. The Miami Herald (11/14, Wieder, Hall, 1.09M) reports, "A Justice Department look-back report into its abortive 2008 prosecution of Jeffrey Epstein found that the Federal Bureau of Investigation had planned to arrest Jeffrey Epstein in May 2007, but pulled back after the U.S. Attorney's Office

y's Office for the Southern District of Florida, led by former Labor Secretary Alexander Acosta, frowned on the plan. The report also concludes that Epstein wasn't assisting the federal government in prosecuting Wall Street traders behind the collapse of investment bank Bear Stearns or serving as an "in

WTKR-TV Norfolk, VA (11/15, 163K) reports Bradley Jeffrey-Moe "was convicted Friday on charges of receivin

nited States as children because his appointment to the top position in the department did not appear to be lawful." In "an unusual Saturday ruling" Garaufis "said...that the `plain text' of the department's order of succession showed that Wolf's ascension to acting secretary did not follow established l

rm. Judge Rules Wolf Serving Illegally, Invalidates His Suspension Of DACA. The Washington Post (11/15, Sacchetti, 14.2M) reports US District Judge Nicholas G. Garaufis of New York "has ruled that acting Homeland Security Secretary Chad Wolf lacked the authority to limit the work permits of hundreds of thousands of

fore Plea Deal. The Miami Herald (11/14, Wieder, Hall, 1.09M) reports, "A Justice Department look-back report into its abortive 2008 prosecution of Jeffrey Epstein found that the Federal Bureau of Investigation had planned to arrest Jeffrey Epstein in May 2007, but pulled back after the U.S. Attorney's Office

y's Office for the Southern District of Florida, led by former Labor Secretary Alexander Acosta, frowned on the plan. The report also concludes that Epstein wasn't assisting the federal government in prosecuting Wall Street traders behind the collapse of investment bank Bear Stearns or serving as an "in

WTKR-TV Norfolk, VA (11/15, 163K) reports Bradley Jeffrey-Moe "was convicted Friday on charges of receivin

nited States as children because his appointment to the top position in the department did not appear to be lawful." In "an unusual Saturday ruling" Garaufis "said...that the `plain text' of the department's order of succession showed that Wolf's ascension to acting secretary did not follow established l

rm. Judge Rules Wolf Serving Illegally, Invalidates His Suspension Of DACA. The Washington Post (11/15, Sacchetti, 14.2M) reports US District Judge Nicholas G. Garaufis of New York "has ruled that acting Homeland Security Secretary Chad Wolf lacked the authority to limit the work permits of hundreds of thousands of

fore Plea Deal. The Miami Herald (11/14, Wieder, Hall, 1.09M) reports, "A Justice Department look-back report into its abortive 2008 prosecution of Jeffrey Epstein found that the Federal Bureau of Investigation had planned to arrest Jeffrey Epstein in May 2007, but pulled back after the U.S. Attorney's Office

y's Office for the Southern District of Florida, led by former Labor Secretary Alexander Acosta, frowned on the plan. The report also concludes that Epstein wasn't assisting the federal government in prosecuting Wall Street traders behind the collapse of investment bank Bear Stearns or serving as an "in

WTKR-TV Norfolk, VA (11/15, 163K) reports Bradley Jeffrey-Moe "was convicted Friday on charges of receivin

nited States as children because his appointment to the top position in the department did not appear to be lawful." In "an unusual Saturday ruling" Garaufis "said...that the 'plain text' of the department's order of succession showed that Wolf's ascension to acting secretary did not follow established l

rm. Judge Rules Wolf Serving Illegally, Invalidates His Suspension Of DACA. The Washington Post (11/15, Sacchetti, 14.2M) reports US District Judge Nicholas G. Garaufis of New York "has ruled that acting Homeland Security Secretary Chad Wolf lacked the authority to limit the work permits of hundreds of thousands of

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 &

ng. The government implicitly concedes as much. In a footnote, the government acknowledges the decision in United States v. Raniere, in which Judge Garaufis ordered a Daubert hearing on the government's proposed expert testimony on grooming. 2019 WL 2212639, at *7-8. In that case, however, the government

orn/2020/09/30/us/elections/with-remarlcs- about-poll-watchers-and-the-supreme-court-trump-stepped-up-attempts-to-sow-doubt-on-the-vote.html> (9/30, Epstein, Thrush, 18.61 M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre- emptively argued that Democratic elections

continued loyalty to NXIVM's founder Keith Raniere and made `obsessive' attempts to investigate and intimidate possible critics of NXIVM," but Judge Garaufis "believed she deserved additional time. He gave her almost seven years in prison, a $500,000 fine and $96,605 restitution to be paid to one of the

included the involvement of top officials, including the president and Vice President Mike Pence." In a separate artide, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections

ontinued loyalty to NXIVM's founder Keith Raniere and made 'obsessive' attempts to investigate and intimidate possible critics of NXIVM," but Judge Garaufis "believed she deserved additional time. He gave her almost seven years in prison, a $500,000 fine and $96,605 restitution to be paid to one of the v

included the involvement of top officials, including the president and Vice President Mike Pence." In a separate article, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections

ontinued loyalty to NXIVM's founder Keith Raniere and made `obsessive' attempts to investigate and intimidate possible critics of NXIVM," but Judge Garaufis "believed she deserved additional time. He gave her almost seven years in prison, a $500,000 fine and $96,605 restitution to be paid to one of the v

included the involvement of top officials, including the president and Vice President Mike Pence." In a separate article, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections

ontinued loyalty to NXIVM's founder Keith Raniere and made 'obsessive' attempts to investigate and intimidate possible critics of NXIVM," but Judge Garaufis "believed she deserved additional time. He gave her almost seven years in prison, a $500,000 fine and $96,605 restitution to be paid to one of the v