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

provide detailed and corroborating accounts of the Defendant's alleged role in enticing minors to engage in sex acts."); see also United States v. Curley, 639 F.3d 50, 59 (2d Cir. 2011) (explaining in an interstate stalking case that evidence of earlier abuse that was "similar in nature and severity"

EFFREY E EPSTEIN 241005 LARRY VISOSKI 2-69016 50.00 439952 Total Payments and Crocks 4127,403.06 Detail in:Maw sonkudame Payments 07/13/16° JEFFREY E EPSTEIN 07/I3/16• JEFFREY E EPSTEIN Credits Amount ONLINE PAYMENT-THANK YOU ONLINE PAYMENT -THANK YOU -$27,003.55 -899,999.99 Amount 07/27/16 LARRY VI

2-61013 Amount 08/11/16 THE PALM BEACH POST (800)926-7678 FL NEWSPAPER 08/11/16 TRISTAR WORLDWIDE TRISTAR WORLDWI BEVERLY MA 851258601730 JEFF EPSTEIN 08 06 16 BED BEDFORD HANSCO TRANSPORTATION SERVICES $14.69 $258.75 08/11/16 TRISTAR WORLDWIDE TRISTAR WORLDWI $230.00 BEVERLY MA 8512585021

an Express@ TraditionalWoPliFaAcrE COPY JEFFREY E EPSTEIN Closing Date 06/10/16 P 15/29 Account Ending 2

r American Express@ TraditionalWoPliFaAcrE COPY JEFFREY E EPSTEIN Closing Date 06/10/16 P 15/29 Account

ent Type: ADDITIONAL COLLECTION Date of Departure:07/10 $93.40 $25.00 07/10/16 JETBLUE AIRWAYS9010001 JETBLUE NY JETBLUE AIRWAYS From: To: Curley Class: JACKSONVILLE INTER FTLAUDERDALE/HOLL 86 N/A YY 00 N/A YY 00 N/A YY CO Ticket Number: Date of Departure:07/11 Passenger Name: V

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 &

6 United States v. Cummings, 60 F. Supp. 3d 434 (S.D.N.Y. 2014) vacated on other grounds 858 F.3d 763 (2d Cir. 2017) 6, 7, 8, 9 United States v. Curley, 639 F.3d 50 (2d Cir. 2011) 5, 6, II, 13 United States v. Dolney, No. 04-CR-159 (NGG), 2005 WL 2129169 (E.D.N.Y. Sept. I, 2005) 10, 15 United S

s. Maxwell's alleged enticement and/or transportation of Accuser-1. The indictment alleges that Ms. Maxwell engaged in group sexual encounters with Jeffrey Epstein and Accuser-1 and that, on at least one occasion, Ms. Maxwell enticed or caused Accuser-1 to travel from Florida to New York for the purpose of enga

least one occasion, Ms. Maxwell enticed or caused Accuser-1 to travel from Florida to New York for the purpose of engaging in such encounters with Epstein. But to do so, it must rely on the accusations of a single individual regarding I This individual is described in the indictment as Minor Victim-3.

Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), affd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 7 United States v. Curley, 639 F.3d 50 (2d Cir. 2011) 10 United States v. Greebel, No. 15-cr-637 (KAM), 2017 WL 3610570 (E.D.N.Y. Aug. 4, 2017) 5 United States v. Hsia,

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 &

6 United States v. Cummings, 60 F. Supp. 3d 434 (S.D.N.Y. 2014) vacated on other grounds 858 F.3d 763 (2d Cir. 2017) 6, 7, 8, 9 United States v. Curley, 639 F.3d 50 (2d Cir. 2011) 5, 6, II, 13 United States v. Dolney, No. 04-CR-159 (NGG), 2005 WL 2129169 (E.D.N.Y. Sept. I, 2005) 10, 15 United S

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 &

No. 07 CR 556, 2009 WL 3617448 (N.D. III. Oct. 27, 2009) 20, 21 United States v. Cummings, 60 F. Supp. 3d 434 (S.D.N.Y. 2014) 26 United States v. Curley, 639 F.3d 50 (2d Cir. 2011) 26 United States v. Curley, No. SI 08 Cr. 404 (SCR), 2009 WL 10688209 (S.D.N.Y. Jul. 15, 2009) 26 United States v.

nual Income December 1, 2018 - December 31,2018 J EPSTEIN VIRGIN ISLANDS Account Quantity Number Activi

,612.39 $13,612.39 6,810.54 $6,810.54 0.00 $0.00 240.91 $240.91 2.19% 2.26% TOTAL CASH, MONEY FUNDS. AND BANK DEPOSITS Dale Acquired Curley Unit God EQUITIES 97 00% of Portfolio Common Stocks $13,612.39 Cost earls Market Price $6,810.54 Market Value $0.00 Unrealized Gain Loss

nual Income December 1, 2018 - December 31,2018 J EPSTEIN VIRGIN ISLANDS Account Quantity Number Activi

,612.39 $13,612.39 6,810.54 $6,810.54 0.00 $0.00 240.91 $240.91 2.19% 2.26% TOTAL CASH, MONEY FUNDS. AND BANK DEPOSITS Dale Acquired Curley Unit God EQUITIES 97 00% of Portfolio Common Stocks $13,612.39 Cost earls Market Price $6,810.54 Market Value $0.00 Unrealized Gain Loss

nual Income December 1, 2018 - December 31,2018 J EPSTEIN VIRGIN ISLANDS Account Quantity Number Activi

,612.39 $13,612.39 6,810.54 $6,810.54 0.00 $0.00 240.91 $240.91 2.19% 2.26% TOTAL CASH, MONEY FUNDS. AND BANK DEPOSITS Dale Acquired Curley Unit God EQUITIES 97 00% of Portfolio Common Stocks $13,612.39 Cost earls Market Price $6,810.54 Market Value $0.00 Unrealized Gain Loss