Epstein Secrets

, Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at *7 (S.D.N.Y. May 13, 2021). Their decisions are consistent with the vast majority of courts to c

ed on the admissibility of a grooming expert, it has previously recognized the academic literature on grooming to facilitate sexual abuse of minors. See United States v. Brand, 467 F.3d 179, 203 (2d Cir. 2006). The Defense cites to several contrary articles that suggest experts disagree on the kinds of behaviors

63. Identical testimony was admitted by Judge Furman in United States v. Dupigny, No. 18- Cr.-528 (JMF) (S.D.N.Y. 2019), Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (

ense may make arguments attacking the credibility of victims, the Government is free to argue that these witnesses are, in fact, victims of a crime. Cl United States v. Thai, 29 F.3d 785, 807 (2d Cir. 1994) (explaining that prosecutors may also "respond to an argument that impugns its integrity or the integrity

y this form of testimony, as explained above. To the extent Raymond stands for such a broad proposition, it is contrary to the law of this Circuit. See United States v. Joseph, 542 F.3d 13, 21-22 (2d Cir. 2008), abrogated on other grounds as recognized by United States v. Ferguson, 676 F.3d 260, 276 n.14 (2d Cir.

econd alterations in original) (citations and internal quotation marks omitted). That point is particularly true in sex trafficking cases. As Judge Engelmayer explained when evaluating the testimony of a similar expert in a sex trafficking case, analyzing error rates is an "unusually poor fit" in this are

, Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at *7 (S.D.N.Y. May 13, 2021). Their decisions are consistent with the vast majority of courts to c

ed on the admissibility of a grooming expert, it has previously recognized the academic literature on grooming to facilitate sexual abuse of minors. See United States v. Brand, 467 F.3d 179, 203 (2d Cir. 2006). The Defense cites to several contrary articles that suggest experts disagree on the kinds of behaviors

63. Identical testimony was admitted by Judge Furman in United States v. Dupigny, No. 18- Cr.-528 (JMF) (S.D.N.Y. 2019), Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (

, Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (DLC), 2021 WL 1947503, at *7 (S.D.N.Y. May 13, 2021). Their decisions are consistent with the vast majority of courts to c

ed on the admissibility of a grooming expert, it has previously recognized the academic literature on grooming to facilitate sexual abuse of minors. See United States v. Brand, 467 F.3d 179, 203 (2d Cir. 2006). The Defense cites to several contrary articles that suggest experts disagree on the kinds of behaviors

63. Identical testimony was admitted by Judge Furman in United States v. Dupigny, No. 18- Cr.-528 (JMF) (S.D.N.Y. 2019), Dkt. No. 198 at 27, by Judge Engelmayer in United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y. 2020), Dkt. No. 335 at 24-30, and by Judge Cote in United States v. Torres, No. 20-CR-608 (

ade and will continue to make best efforts to process records in connection with its reliance on other exemptions and Exemption 7(A) on the basis of United States v. Tartaglione, I 6-cr-832 (KMK). The Government also intends to precisely mark out its reliance on Exemption 7(A) on the basis of the Noel prosecut

rn District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOR"), 5 U.S.C. § 552, action brought

ade and will continue to make best efforts to process records in connection with its reliance on other exemptions and Exemption 7(A) on the basis of United States v. Tartaglione, I 6-cr-832 (KMK). The Government also intends to precisely mark out its reliance on Exemption 7(A) on the basis of the Noel prosecut

rn District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOR"), 5 U.S.C. § 552, action brought

e are withheld under which FOIA Exemption and, if a portion or the entire page is withheld under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr-832 (KMK), or United States v. Noel, 19-cr-830 (AT), is the basis for the exemption. Because of technological and other const

rn District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOR"), 5 U.S.C. § 552, action brought

nt with the Government's May 24, 2021, letter to the Court, ECF No. 59, Judge Tones entered deferred prosecution agreements as to both defendants in United States v. Noel, 19 Cr. 830 (Al). See Deferred Prosecution Agreement as to Michael Thomas, ECF No. 56, United States v. Noel, 19 Cr. 830 (AT); Deferred Pros

rn District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, action brought