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 &

n the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal ag

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 &

g), 108 Stat. 1796 6 iii EFTA00086739 PRELIMINARY STATEMENT Ghislaine Maxwell respectfully submits this Memorandum in Support of her Motion to Strike Surplusage from the Indictment ("Motion"). Although Ms. Maxwell is charged with conspiring to cause individuals to travel in interstate or foreign commerce to

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 &

n the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal ag