Epstein Secrets

personal matters and contacts to which he attends in Florida. For example, beginning in 2002, Mr. Epstein visited his mother nearly every weekend in Palm Beach until she passed away in April, 2004. 5 As previously set forth herein, and as more fully explained in other submissions related to this case, the r

d it really fast because I didn't want to make it sound like I was lying or anything. Tr. at 38-39. Thus, consistent with the guidance provided in Franks v. Delaware, 438 U.S. 154 (1978), the search warrant affidavit in this case reveals knowing and reckless falsehoods and omitted material information. This is p

personal matters and contacts to which he attends in Florida. For example, beginning in 2002, Mr. Epstein visited his mother nearly every weekend in Palm Beach until she passed away in April, 2004. 5 As previously set forth herein, and as more fully explained in other submissions related to this case, the r

aid it really fast because I didn't want to make it sound like I was lying or anything. . at 38-39. Thus, consistent with the guidance provided in Franks v. Delaware, 438 U.S. 154 (1978), the search warrant affidavit in this case reveals knowing and reckless falsehoods and omitted material information. This is p

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

tain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the affidavit, (ii) "the alleged falsehoods or omissions were nece

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

tain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the affidavit, (ii) "the alleged falsehoods or omissions were nece

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

tain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the affidavit, (ii) "the alleged falsehoods or omissions were nece