Epstein Secrets

ce. At the time of certain of those phone calls, .EPSTEIN and Emplpyeer2 were in New YOrki New York. Addit

In so doing, :EPSTEIN maintained a steady supply Or new victims to eXpleit. The New York Residence 8. At all times relevant to this indictment, JEFFREY EPSTEIN, the defendant, possessed' and Controlled a multi-story pritate residence on the Upper EaSt Side of Manhattan, New York, the New York Resident*: Be

York-based victims, Many. Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant; on Multiple additional. occasions. 18. JEFFREY. EPSTEIN, the defendant, who during the relevant time period was frequently in NeW YOrki *mild arrange for Employee-2-ox other employee$ to contact

y pritate residence on the Upper EaSt Side of Manhattan, New York, the New York Resident*: BetWeen at least in or about 2002 and in Or about 2005, Sp$TEIN abused numerous minor victims at the New York Residence by canSing these victims to be recruited to engage in paid sex acts With himL 3 EFTA00164

ing the relevant time period was frequently in NeW YOrki *mild arrange for Employee-2-ox other employee$ to contact victims by phone in ,advance of EPETEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls t

harbored, transported, provided, and obtained numerous 11 EFTA00164820 individuals who were less than 18 years old, including but not limited to Minor Victim-I, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York. . (Title 18, United. States Cod

In so doing, :EPSTEIN maintained a steady supply Or new victims to eXpleit. The New York Residence 8. At all times relevant to this indictment, JEFFREY EPSTEIN, the defendant, possessed' and Controlled a multi-story pritate residence on the Upper EaSt Side of Manhattan, New York, the New York Resident*: Be

ce. At the time of certain of those phone calls, .EPSTEIN and Emplpyeer2 were in New YOrki New York. Addit

York-based victims, Many. Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant; on Multiple additional. occasions. 18. JEFFREY. EPSTEIN, the defendant, who during the relevant time period was frequently in NeW YOrki *mild arrange for Employee-2-ox other employee$ to contact

y pritate residence on the Upper EaSt Side of Manhattan, New York, the New York Resident*: BetWeen at least in or about 2002 and in Or about 2005, Sp$TEIN abused numerous minor victims at the New York Residence by canSing these victims to be recruited to engage in paid sex acts With himL 3 EFTA00164

ing the relevant time period was frequently in NeW YOrki *mild arrange for Employee-2-ox other employee$ to contact victims by phone in ,advance of EPETEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls t

harbored, transported, provided, and obtained numerous 11 EFTA00164669 individuals who were less than 18 years old, including but not limited to Minor Victim-I, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York. . (Title 18, United. States Cod

ointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN. d. In or about 2004, Minbr Victim-2 was recruited to engage in sex acts with OSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars after each encou

enses") described as follows: 1. Any documents or communications with or regarding victims or potential victims of the Subject Offenses or between EPSTEIN and co-conspirators to the Subject Offenses; 2. Any photographs of victims or potential victims of the Subject Offenses or co- conspirators to the

the "president and sole beneficial owner" of Nautilus, Inc. 21. In addition, I believe that up until his arrest, the Virgin Islands Residence was JEFFREY EPSTEIN's principal residence. In particular, I have reviewed sex offender registration data, and have learned that, on or about June 17, 2019, EPSTEIN listed

tion, storage capacity, and computer habits. 33. Based on the foregoing, I respectfully submit there is probable cause to believe that evidence of JEFFREY EPSTElN's commission of the Subject Offences is likely to be found on the Subject Items. III. Procedures for Searching ESI A. Review of ESI 34.

er labeled "kitchen mac," which was recovered from a desk in the main residence on the island ("Subject Device-1"); b. A silver Mac laptop labeled "JE big laptop," bearing serial number W8 111772QT, which was recovered from a desk in the main residence on the island ("Subject Device-2"); 3 2017.

: a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-I, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after w

ce. At the time of certain of those phone calls, .EPSTEIN and Emplpyeer2 were in New YOrki New York. Addit

In so doing, :EPSTEIN maintained a steady supply Or new victims to eXpleit. The New York Residence 8. At all times relevant to this indictment, JEFFREY EPSTEIN, the defendant, possessed' and Controlled a multi-story pritate residence on the Upper EaSt Side of Manhattan, New York, the New York Resident*: Be

York-based victims, Many. Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant; on Multiple additional. occasions. 18. JEFFREY. EPSTEIN, the defendant, who during the relevant time period was frequently in NeW YOrki *mild arrange for Employee-2-ox other employee$ to contact

y pritate residence on the Upper EaSt Side of Manhattan, New York, the New York Resident*: BetWeen at least in or about 2002 and in Or about 2005, Sp$TEIN abused numerous minor victims at the New York Residence by canSing these victims to be recruited to engage in paid sex acts With himL 3 EFTA01648

ing the relevant time period was frequently in NeW YOrki *mild arrange for Employee-2-ox other employee$ to contact victims by phone in ,advance of EPETEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls t

harbored, transported, provided, and obtained numerous 11 EFTA01648874 individuals who were less than 18 years old, including but not limited to Minor Victim-I, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York. . (Title 18, United. States Cod

11 GX-110 Photograph of SDNY GM 02753621 2021.10.11 GX-III Photograph of Ghislaine Maxwell SDNY GM 02753632 2021.10.11 GX-112 Photograph of Jeffery Epstein SDNY GM 02753623 2021.10.11 GX-113 Photograph of Minor Victim-5# Made Available for Review 2021.10.11 GX-114 Photograph of Minor Victim-5# S

SDNY GM 02753644-2753692 2021.10.11 GX-328 Photograph of Zorro Ranch Entryway SDNY GM 02753644-2753692 2021.10.11 GX-329 Photograph ofiefircy Epstein and SDNY GM 02753644-2753692 2021.10.11 GX-330 Photograph of SDNY GM 02753644-2753692 2021.10.11 GX-331 Photograph of Ghislaine Maxwell. and

753644-2753692 2021.10.11 GX-315 Photograph of Jeffrey E stein and Plane SDNY GM 02753644-2753692 2021.1

I Professional Children's School GX Description Bates Number/Identifier Produced to Defense GX-761 Professional Children's School Records for Minor Victim-I# SDNY GM 000055 II -SDNY GM 00005514 2021.10.11 780 Series Records Palm Beach County School District GX Description Bates Number/Identifier

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 &

s individual is described in the S2 Superseding Indictment as Minor Victim-3. Similarly, we refer to the individuals identified in the indictment as Minor Victim-I and Minor Victim-2 as Accuser-I and Accuser-2, respectively. EFTA00074483 Accuser-3 were illegal. Indeed, referring to Accuser-3 in the indictmen

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 &

s individual is described in the S2 Superseding Indictment as Minor Victim-3. Similarly, we refer to the individuals identified in the indictment as Minor Victim-I and Minor Victim-2 as Accuser-I and Accuser-2, respectively. EFTA00087778 Accuser-3 were illegal. Indeed, referring to Accuser-3 in the indictmen