Epstein Secrets

te in the jury room. You may take a copy of these instructions with you into the jury room. Adapted from the charge of the Hon. Alison J. Nathan in United States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 17 Cr. 151 (AJN). 1 EFTA00074504 Role of the Jury Your role is to pass upon and dec

in United States v. Purcell, 18 Cr. 081 (DLC); and the charge of the Hon. Ann M. Donnelly in United States v. Kelly, 19 Cr. 286 (AMD) (E.D.N.Y.). See United States v. Murphy, 942 F.3d 73, 79-84 (2d Cir. 2019) (holding under 18 U.S.C. § 2423(b) that a defendant must know the age of the victim where the victim's

Castel in United States v. William Walters, 16 Cr. 338 (PKC); and Sand et al., Modern Federal Jury Instructions, Instr. 3A-2. See United States v. Lange, 834 F.3d 58, 76 (2d Cir. 2016) ("Conscious avoidance may not be used to support a finding as to . . .intent to participate in a conspiracy, but it

inor victim testified that she was in SDNY when the defendant first contacted her over Facebook and encouraged her to travel to meet him in Queens. See United States v. Walsh, 827 F. App'x 30, 33 (2d Cir. 2020). The remaining conduct, including in-person grooming and all commercial sex acts, then took place in ED

nd Three. Conspiracy charges may be brought "in any district in which an overt act in furtherance of the conspiracy was committed." United States v. Lange, 834 F.3d 58, 68 (2d Cir. 2016). Here, the calls from New York to schedule appointments and the packages 2021.01.26 EFTA_00023140 EFTA02731246

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be of legal claming ego le consumo alcoholic beverages. Fleas* drink responsibly. American Express reserves the right to remove any person born the Lange lot inappropnato behavior ce failure to adhere to rules. including, but not smiled to. conduct that is disruptive. abusive or violent. Access is wine

, e.g., United States v. Salameh, 152 F.3d 88, 118-20 (2d Cir. 1998) (defendant pled guilty in EDNY to using the passport of another person to enter the United States and later charged in SDNY with related, but distinct terrorism offenses); United States v. Gonzalez, 93 F. App'x 268, 269-70 (2d Cir. 2004) (defenda

much to prevent the criminal from being twice punished for the same offense as from being twice tried for it. Pearce, 395 U.S. at 717-18 (quoting Lange, 85 U.S. (18 Wall.) at 168) (emphasis added). Here, it is beyond dispute that Epstein was already punished for the offenses covered by the NPA. The

in United States v. Gebbie, 294 F.3d 540, 544-52 (3d Cir. 2002), holding that "when a United States Attorney negotiates and contracts on behalf of `the United States' or 'the Government' in a plea agreement for specific crimes, that attorney speaks for and binds all of his or her fellow United States Attorneys wi

The Court Should Grant Ms. Maxwell's Other Requested Relief. 16 CONCLUSION 17 i EFTA00104412 TABLE OF AUTHORITIES Page(s) Cases Ex parte Lange, 85 U.S. (18 Wall.) 163 (1873) 11 Morris v. Reynolds, 264 F.3d 38 (2d Cir. 2001) 12 North Carolina v. Pearce, 395 U.S. 711 (1969) II, 12, 13

oronavirus-usa-deaths/u-s-surpasses-grim-milestone-of- 200000-covid-19-deaths-idUSKCN26C11Z> (9/22, S) reports, "Six out of every 10,000 residents in the United States has died of the virus, according to Reuters data, one of the highest rates among developed nations." The CBS Evening News <https://playvideo.bulleti

Reuters <https://www.reuters.corrilarticle/us-usa-election-cyber/us-warns-foreign-actors-aim-to-sow-doubts- over-mail-in-voting-idUSKCN26D34C> (9/22, Lange) reports US federal law enforcement and "cybersecurity agencies on Tuesday warned that 'foreign actors' will likely try to discredit the November pr

untries." According to the limes, "Italy, once the center of the pandemic, reported 17 deaths on Monday; Germany reported 10 deaths the same day. In the United States that day, 428 people were reported to have died of the virus." Reuters (9/22, S) reports, "Six out of every 10,000 residents in the United States ha

nd CNN (9/22, 83.16M) also reports in a video. US Warns "Foreign Actors" May Introduce Disinformation On Delayed Election Results. Reuters (9/22, Lange) reports US federal law enforcement and "cybersecurity agencies on Tuesday warned that `foreign actors' will likely try to discredit the November pr

untries." According to the Times, "Italy, once the center of the pandemic, reported 17 deaths on Monday; Germany reported 10 deaths the same day. In the United States that day, 428 people were reported to have died of the virus." Reuters (9/22, 5) reports, "Six out of every 10,000 residents in the United States ha

nd CNN (9/22, 83.16M) also reports in a video. US Warns "Foreign Actors" May Introduce Disinformation On Delayed Election Results. Reuters (9/22, Lange) reports US federal law enforcement and "cybersecurity agencies on Tuesday warned that `foreign actors' will likely try to discredit the November pr