Epstein Secrets

llowing: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York. NY 10007 s/ 8 EFTA00040134

667, 684, (1985). Full and complete cross-examination of the Accusers is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Ms. Maxwell, as well as others. Cf. Moore v. Marr, 254 F.3d 1235, 1244 (10th Cir. 2001) (noting that witnesses' "a

llowing: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York. NY 10007 s/ Nicole Simmons 8

667, 684, (1985). Full and complete cross-examination of the Accusers is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Ms. Maxwell, as well as others. Cf. Moore v. Marr, 254 F.3d 1235, 1244 (10th Cir. 2001) (noting that witnesses' "a

f New York The SihioJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 November 18, 2

impeachment information because "[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by

f New York The SilWoJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 November 18, 2

impeachment information because "[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by