Epstein Secrets

native, the Court Should Preclude the Government and Accuser-3 from Representing that Accuser-3 Was a "Minor," or that She Was "Sexually Abused" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00074480 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merre

was a "minor" at the time of the alleged sex acts, (2) to preclude the government and Accuser-3 from representing that she was "sexually abused" by Jeffrey Epstein, and (3) for an appropriate limiting instruction concerning Accuser-3's testimony. PRELIMINARY STATEMENT The government and the defense agree on at

LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ited States v. Mahsffr, 477 F. Supp. 2d 560 (E.D.N.Y. 2007) vacated in part on other grounds 285 Fed. App'x 797 (2d Cir. 2008) 9 United States v. McCallum, 584 F.3d 471 (2d Cir. 2009) 5, 6, 11 United States v. Mills, 895 F.2d 897 (2d Cir. 1990) 12 United States v. Nektalov, 325 F. Supp. 2d 367 (S

native, the Court Should Preclude the Government and Accuser-3 from Representing that Accuser-3 Was a "Minor," or that She Was "Sexually Abused" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00087775 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merre

was a "minor" at the time of the alleged sex acts, (2) to preclude the government and Accuser-3 from representing that she was "sexually abused" by Jeffrey Epstein, and (3) for an appropriate limiting instruction concerning Accuser-3's testimony. PRELIMINARY STATEMENT The government and the defense agree on at

ER-3 Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ited States v. Mahsffr, 477 F. Supp. 2d 560 (E.D.N.Y. 2007) vacated in part on other grounds 285 Fed. App'x 797 (2d Cir. 2008) 9 United States v. McCallum, 584 F.3d 471 (2d Cir. 2009) 5, 6, 11 United States v. Mills, 895 F.2d 897 (2d Cir. 1990) 12 United States v. Nektalov, 325 F. Supp. 2d 367 (S

itico, some lawmakers "had expressed concern over Lander's selection, especially related to two meetings he had with late financier and sex offender Jeffrey Epstein in the spring of 2012." Politico (5/20, Arciga, Din, 6.73M) reports Biden "tapped Lander to lead the office in early January, following his stint a

had with late financier and sex offender Jeffrey Epstein in the spring of 2012." Politico (5/20, Arciga,

tings he had with late financier and sex offender Jeffrey Epstein in the spring of 2012." Politico (5/20,

tain's MI5, "has accused Facebook of giving terrorists and other dangerous criminals a 'free pass' by allowing stronger encryption on its network." McCallum "said hundreds of counterterrorism investigations by the security service would be thwarted by the social media giant's plans to install end-to-end

with current Deputy Director Dan Bongino. The appointment comes after Bongino reportedly clashed with Attorney General Pam Bondi over the release of Jeffrey Epstein files. "I am proud to announce I have accepted the role of Co-Deputy Director of the FEW" Bailey wrote in a brief post on X. "I extend my thanks to

n CRIMINAL INVESTIGATIONS • House Panel to Make Epstein Files Public After Redactions to Protect Victim I

th Attorney General Pam Bondi over the release of Jeffrey Epstein files. "I am proud to announce I have ac

stance of the FBI's Little Rock field office. FBI Believes More May Be Involved in Louisiana Homicide The Shreveport-Bossier City Advocate (08/19, McCallum) reported that the FBI and US Attorneys are investigating the homicide of Billy Jamison, 67, who was fatally shot during a robbery at a Walgreens on

From: Sent: To: Subject: Thursda November 4, 2010 6:04 AM Fwd: J. Epstein I'm ahead of ya! ; ) I though= I copied you on this. Ugh..I'm bad about that! Begin forw=rded message: From: Mary=McCallum < > Date: November 4

Sorry to bother you, but just wondering wh= we should keep an eye out for upon our arrival into the Abu Dhabi airport?=Will someone have a sign with Jeffrey's name, or the name of the resort? Best, </=tml>= EFTA_R1_01220053 EFTA02317512

bject: Thursda November 4, 2010 6:04 AM Fwd: J. Epstein I'm ahead of ya! ; ) I though= I copied you on

, 2010 6:04 AM Fwd: J. Epstein I'm ahead of ya! ; ) I though= I copied you on this. Ugh..I'm bad about that! Begin forw=rded message: From: Mary=McCallum < > Date: November 4 2010 5:45:31 AM GMT+01.00 To:</=> ><=r>Subject: RE: J. Epstein No trouble, he will be met by our Pro=ocol department - man o