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er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage from an indictment will be granted only where the challenged allegations are
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage from an indictment will be granted only where the challenged allegations are
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage from an indictment will be granted only where the challenged allegations are
release program starting 10/10/08 and ending 07/22/09. If you have any questions or concerns please contact me. Deputy 3228 Gum Club Road • West Patin Beach, Florida 33406-3001 • • http://vesettpbso.org - - WM014 donne* EFTA00231496 A51 Letter from Jack A. Goldberger to NYS Sex Offender Registry R
268 (4th Dep't 200'7) 31 People v. Ferguson, 53 A.D.3d 571 (2d Dep't 2008) 39 People v. Gilbert, 78 A.D.3d 1584 (4th Dep't 2010) 47 People v. Jimenez, 178 Misc. 2d 319, 679 N.Y.S.2d 510 (Sup. Ct. Kings Cty. 1998) 18 People v. Johnson, 11 N.Y.3d 416 (2008) 18 People v. Jordan, 31 A.D.3d 1196
Entities connected to both Palm Beach and Jimenez

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATIONJack Goldberger
PERSON
New York
LOCATION
New York City
LOCATION
Eric Holder
PERSON
Marc Rich
PERSON
Donald Trump
PERSON
Lesley Groff
PERSONJane Doe
PERSONFBI
ORGANIZATION
Bradley Edwards
PERSON
U.S. Virgin Islands
LOCATIONthe Southern District
LOCATION
Bill Clinton
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION