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t could not have proven Epstein's residency by any alternative means. Similarly, the Defendant does not explain why the flight manifests that pilot Larry Visoski delivered to Epstein's office in New York have been lost. See Trial Tr. at 172. In short, the Defendant fails to show that the absence of documentar
xplain why the flight manifests that pilot Larry Visoski delivered to Epstein's office in New York have be
has sufficient notice of the Government's theory at trial, she cannot claim that she was unfairly or substantially prejudiced. See United States v. Kaplan, 490 F.3d 119, 129-30 (2d Cir. 2007). Finally, the Court bears in mind that the Defendant brings her motion pursuant to Rule 33, which permits the
sion in December 2010. In November 2021 Lawrence Visoski, Epstein's pilot, testified in co w flew in Epst
net an alleged victim of Epstein, said in a federal lawsuit that she had see Andrew at Epstein's New ork mansion in December 2010. In November 2021 Lawrence Visoski, Epstein's pilot, testified in co w flew in Epstein's private plane along with other prominent individuals, includi an 17t t. he otice any sexua
41241 On 29 October 2021, Andrew's lawyers filed a response, their client "unequw iuffre's false allenations".l122= On 12 January 2022 Judge Kaplan rejected Andrew's attempts to dismiss the case, allowing the sexual abuse lawsuit to proceed. frallii In February, the case was settled out of court
on in December 2010.41) In November 2021 Lawrence Visoski, Epstein's pilot, testified in co its-ti: jai-th
In Jul 0. Caroline Ka Sr an alleged victim of Epstein, said in a federal lawsuit that she had kirk mansion in December 2010.41) In November 2021 Lawrence Visoski, Epstein's pilot, testified in co its-ti: jai-that w flew in Epstein's private plane along with 2ther prominent individuals, incl 1 Vsoski-statet
29 October 2021, Andrew's lawyers filed a response, their client "unequtvocall aeries iuffre's false allegations".U211121) On 12 January 2022 Judge Kaplan rejected Andrew's attempts to dismiss the case, allowing the sexual abuse lawsuit to proceed. U22)021) in February, the case was settled out of cour
Associated Aircraft Group, Inc Quote for Aircraft Services ASSOC A"°A ,PICRA GROUP Quoted For: Freedom Air Quote Number: 4843 Contact: Visoski, Larry Date Quoted: 01 May 2013 Address: 575 Lexington Avenue, 4th Floor New York. NY 10022 USA Phone: Aircraft: SK-76C+ Fax: Tail it: N7
ociated Aircraft Group, Inc Quote for Aircraft Services ASSOC A"°A ,PICRA GROUP Quoted For: Freedom Air Quote Number: 4843 Contact: Visoski, Larry Date Quoted: 01 May 2013 Address: 575 Lexington Avenue, 4th Floor New York. NY 10022 USA Phone: Aircraft: SK-76C+ Fax: Tail it: N76TBA E
tin Cenlinnanan oh o% shall be nab^ i to One Turns ad Cohens. "Clara, Lollop Cuallemalhe tees die death. if to Claws ApemanWI...v.6e Caron noll do (Kaplan ...Whey die Flipb1 Sclinhale as lime Tema ad ConlAtatc "Chinks Price" stun do sr paoble ban 6e Oman for theMaier n .4a/cants& Carat Daltrey Corinnwa
ted SEMEpstain's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louel la Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh, (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individu
ouel la Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxbur
dentiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe t
ouel la Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxbur
Kellen (Epstein's number one co-conspirator who was actually named as such in the WA), his housekeeper (Louel la Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh, (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individu
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe tha
Entities connected to both Larry Visoski and Kaplan

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Richard Kahn
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Karyna Shuliak
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Eric Trump
PERSON
David Rodgers
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Bella Klein
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Bedford
LOCATION
Lawrence Krauss
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Ghislaine Maxwell
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FedEx
ORGANIZATION
John F. Kennedy
PERSON
Newark
LOCATIONLeon Black
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Prince Andrew
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Sarah Kellen
PERSONDaphne Wallace
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Woody Allen
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