Epstein Secrets

orts, before his recent incarceration (discussed below), he frequently traveled around the globe in the company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has international contacts, including international financial contac

company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefo

n direct evidence, and, in some cases is even more reliable."' United States v. Ranum, 96 F.3d 1020, 1026 (7th Cir. 1996) (quoting United States v. Hatchett, 31 F.3d 1411, 1421 (7th Cir. 1994 )). For all these reasons, the Court should conclude that Epstein is fraudulently transferring assets. 11 C

orts, before his recent incarceration (discussed below), he frequently traveled around the globe in the company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has international contacts, including international financial contact

company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefor

n direct evidence, and, in some cases is even more reliable.'" United States v. Ranum, 96 F.3d 1020, 1026 (7th Cir. 1996) (quoting United States v. Hatchett, 31 F.3d 1411, 1421 (7th Cir. 1994)). For all these reasons, the Court should conclude that Epstein is fraudulently transferring assets. 11 EFTA

ign presidents, and world leaders are highly relevant and admissible (Motion in Limine 1) .0...... ce ceeeeseeeseeeseeeseeeseeeneeesees 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 3. FOIA responses and related materials are admissible (Motion in Limine 3)....

eeseeeseeeseeeseeeseeeneeesees 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion

7, 1998)... 25 United States v. Dukes, 727 F.2d 34, 37 (2d Cir. 1984) oo. ceiceeccssseeseceseesseeeseesseeeeecseessaeeseeesneeees 17 United States v. Hatchett, 918 F.2d 631, 641 (6th Cir, 1990) oo. eee ceeeesseeseeeseeeseeeseesseeeseeenaeeees 22 United States v. Lujan, No. 05—CR-924 (RB) (D.N.M. Mar. 25, 20

, foreign presidents, and world leaders are highly relevant and admissible (Motion in Limine 1) ..00...0.. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 FOIA responses and related materials are admissible (Motion in Limine 3)......

. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion

7, 1998)... 25 United States v. Dukes, 727 F.2d 34, 37 (2d Cir. 1984) o.oo ccecccecccccccceccceesccessscssseecneeeesstecsseeenees 17 United States v. Hatchett, 918 F.2d 631, 641 (6th Cir. 1990) oo... cccccc cee ceececeeeeeseeessesenees 22 United States v. Lujan, No. 05—CR—-924 (RB) (D.N.M. Mar. 25, 2011) ..