Epstein Secrets

y for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant Unit

c and abusive events is impacted by a number of factors, including the circumstances surrounding the trauma," is "so generic as to be meaningless." (Del Mot. 3 at 17). That opinion is no more generic than the opinion that false memories can be "created as a result of post-event information and occurrenc

New York The Silvio 1 Mollo Building One Saint Andrew's Plaza New York. New York 10007 March 9, 2021

Macalvins report and the underlying documents and determined that report accurately represents the assets held by the Defendant and her spouse. See Del Mot, Ex. P. The Defendant's new bail proposal is based on the numbers derived from the Macalvins report. But even assuming that the financial report p

orney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafaiia agreed to the nonprosecut

he defendant invites the Court to engage in a balancing test that weighs the prejudice to the defendant against the Government's reasons for delay. (Del Mot. 7 at 5,6 n.4). This Court should reject the defendant's invitation. The defendant cites United States v. Brand, 556 F.2d 1312, 1317 n.7 (5th Cir.

hild Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea di

ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February

hild Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea di

ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February