Epstein Secrets

cott Rothstein, David Roden, Debra 'Allegan, 14 Andrew Barnett, TO Bank, Frank Spinoaa, Jennifer IS Ke

if it happened it's relevant to 5 proving that it had happened to your client. 4 The whole point is to prove that it / happened to your client, Donau.* it happened to • other people. And the circumstances, if they can be • similar, that helps as wall. 10 II • You spoke about modus operandi.

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

Thus, the defendant's claim that she no longer has access to certain evidence is not a proper basis to dismiss the Indictment. See United States v. Donau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973) ("A bare allegation that records have been lost or destroyed, which might relate Ig The Government notes t

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

Thus, the defendant's claim that she no longer has access to certain evidence is not a proper basis to dismiss the Indictment. See United States v. Donau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973) ("A bare allegation that records have been lost or destroyed, which might relate Ig The Government notes t