Epstein Secrets

the crime or, if no prosecution is underway, in the district court in which the crime occurred." Since no federal criminal charge was filed against Epstein, petitioners sought relief under the second clause, by filing their emergency petition in the Southern District of Florida on July 7, 2008. Petitio

st Epstein, using the Podhurst Orseck, P.A. law firm, which had been suggested to her in the September 3, 2008 letter. Exhibit B Jane Doe No. 102'. Jeffrey Epstein, Case No. 09-80656-CIV-MARRA (S.D.Fla.). In her complaint against Epstein, Jane Doe #3 stated that she received numerous phone calls from one of Ep

ber 3, 2008 letter. Exhibit B Jane Doe No. 102'. Jeffrey Epstein, Case No. 09-80656-CIV-MARRA (S.D.Fla.).

e entire agreement between the United States and Mr. Epstein." Exhibit A at 3. In January 2009, Jane Doe #3 r

South Carolina, Inc., 239 F.3d 611, 618 (4th Cir. 2001). These CVRA proceedings, however, are ancillary criminal proceedings. See Fed.R.Crim.P. 60, Advisory Committee Note (2008 Adoption)(` This rule implements several provisions of the Crime Victims' Rights Act, codified at 18 U.S.C. § 3771, in judicial proceedings i

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 &

iples, which the Rule contemplates." Id. at 21. Surely that is not right when, as here, the "general principles" are unreliable. Fed. it Evid. 702, Advisory Committee Note (if expert testifies to general principles but not apply them, "the testimony [must] be reliable"). See also Mot. at 10; Raymond, 700 F. Supp. 2d a

Jane Doe No. I and Jane Doe No. 2 became familiar enough with the non-prosecution agreement to both invoke its provisions in their lawsuits against Jeffrey Epstein under 18 U.S.C. § 2255.' United States' Reply in Support of Its Motion to Dismiss for Lack of Subject matter Jurisdiction, D.E. 205-6, Exhibits A —

wsuit was that the government failed to consult with them prior to what they believed would be the disposition of the federal investigation against Epstein. D.E. 1,11 3,4. They knew, at the time their petition was filed, that Epstein had "recently been prosecuted and pleaded guilty, on June 30, 2008, i

h invoke its provisions in their lawsuits against Jeffrey Epstein under 18 U.S.C. § 2255.' United States'

Government has previously explained (see, e.g., D.E. 290 at 1-2), these CVRA proceedings are ancillary criminal proceedings, see Fed.R.Crim.P. 60, Advisory Committee Note (2008 Adoption) ("This rule implements several provisions of the Crime Victims' Rights Act, codified at 18 U.S.C. § 3771, in judicial proceedings i