Epstein Secrets

1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. PairBoca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] Defendant Ghislaine M

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. PairBoca 150 East 10th Avenue Denver, Colora

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

e intersection of criminal procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and practitioners. We expect Professor Gershman to provide testimony on best practices to ensure the integrity

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory of g

into isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

0 Cr. 330 (AJN) Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East lOth Avenue Denver, Colora

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. i

e intersection of criminal procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and practitioners. We expect Professor to provide testimony on best practices to ensure the integrity of any

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr.Mis

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr.Mis aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory of gr

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East lOth Avenue Denver, Colora

e intersection of criminal procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and practitioners. We expect Professor to provide testimony on best practices to ensure the integrity of any

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglitica 150 East 10th Avenue Denver, Color

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

e intersection of criminal procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and practitioners. We expect Professor Gershman to provide testimony on best practices to ensure the integrity

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglluca 150 East 10th Avenue Denver, Colora

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

e intersection of criminal procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and practitioners. We expect Professor Gershman to provide testimony on best practices to ensure the integrity

ualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory

isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations Studies concerning the ac

Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca Denver, Colorado 80203 PH FX www.

roomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. Dr. Di

e intersection of criminal procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and practitioners. We expect Professor Gershman to provide testimony on best practices to ensure the integrity

ses would have been res ipsa, and warranted prosecution to the full extent of the law. The 'Epstein' Case EFTA00064775 But what about cases like Jeffrey Epstein? There seems little question that Epstein, despite his great business success and commendable philanthropic activity, has a sordid history of engagi

cution to the full extent of the law. The 'Epstein' Case EFTA00064775 But what about cases like Jeffrey Epstein? There seems little question that Epstein, despite his great business success and commendable philanthropic activity, has a sordid history of engaging in (criminal) physical relations with

ive, as we ideally might expect them to be. Think Jeffrey Dahmer, Ted Kaczynski, El Chapo, John Gotti, Osa

al activity. Prosecutorial Decision-Making Whenever discussing prosecutorial discretion, one must immediately turn to Professor Bennett Gershman's Prosecutorial Misconduct, 2d Ed., Thomson Reuters. Succinctly, "[t]he prosecutor decides whether or not to bring criminal charges; who to charge; what charges to bring; whet

ach of those cases would have been res ipsa, and warranted prosecution to the full extent of the law. The `Epstein' Case But what about cases like Jeffrey Epstein? There seems little question that Epstein, despite his great business success and commendable philanthropic activity, has a sordid history of engagi

arranted prosecution to the full extent of the law. The `Epstein' Case But what about cases like Jeffrey Epstein? There seems little question that Epstein, despite his great business success and commendable philanthropic activity, has a sordid history of engaging in (criminal) physical relations with

ive, as we ideally might expect them to be. Think Jeffrey Dahmer, Ted Kaczynski, El Chapo, John Gotti, Osa

TA00064793 SDNY News Clips, April 9, 2019 Whenever discussing prosecutorial discretion, one must immediately turn to Professor Bennett Gershman's Prosecutorial Misconduct, 2d Ed., Thomson Reuters. Succinctly, "[t]he prosecutor decides whether or not to bring criminal charges; who to charge; what charges to bring; whet

Just and Proportional Sanctions for Buyers of Sex with Trafficking Victims, 90 N.Y.U. L. Rev. 626, 663 (2015). IV. Case Study: The Prosecution of Jeffrey Epstein A. Background. 1. State Investigation and Criminal Process. 2. Federal Intervention in the State Process. a. The Failure of Federal Prosecutors to

Amendment Right to be Informed of Criminal Charges" as well as the Fifth Amendment Right to Due Process12. 1. Federal Prosecutors Knowingly Misled Epstein and the Courts. Federal prosecutors failed to disclose to Epstein and the courts the absence of a factual predicate for a prosecution and plea unde

mes, 18 U.S.C. § 2422(b), and the Prosecution of Jeffrey Epstein" I. Introduction In 1996, 18 U.S.C. §

a form of prosecutorial misconduct because "defendants may plead to charges beyond their level of culpability"); Michael T. Fisher, Harmless Error, Prosecutorial Misconduct, and Due Process: There's More to Due Process than the Bottom Line, 88 Columbia Law Review 1298 (1988). EFTA00583950 The conditions set forth in

Just and Proportional Sanctions for Buyers of Sex with Trafficking Victims, 90 N.Y.U. L. Rev. 626, 663 (2015). IV. Case Study: The Prosecution of Jeffrey Epstein A. Background. 1. State Investigation and Criminal Process. 2. Federal Intervention in the State Process. a. The Failure of Federal Prosecutors t

Amendment Right to be Informed of Criminal Charges" as well as the Fifth Amendment Right to Due Process12. 1. Federal Prosecutors Knowingly Misled Epstein and the Courts. Federal prosecutors failed to disclose to Epstein and the courts the absence of a factual predicate for a prosecution and plea unde

mes, 18 U.S.C. § 2422(b), and the Prosecution of Jeffrey Epstein" I. Introduction In 1996, 18 U.S.C. §

a form of prosecutorial misconduct because "defendants may plead to charges beyond their level of culpability"); Michael T. Fisher, Harmless Error, Prosecutorial Misconduct, and Due Process: There's More to Due Process than the Bottom Line, 88 Columbia Law Review 1298 (1988). EFTA00584458 The conditions set forth in