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

ellow jurors, and if you apply your own common sense, you will deliberate fairly. Dated: New York, New York October 2021 Respectfully submitted, DAMIAN WILLIAMS [Defense signature block] United States Attorney By: Assistant United States Attorneys 86 EFTA00074589

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.

MERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys

thenticate one, even if the particular water bottle was taken from the locker room before that player joined the Yankees. The same is the case here. See United States v. Al Farekh, 810 F. App'x 21, 24-25 (2d Cir. 2020) (authenticating "handwritten letters" based on their contents and "considerable similarities be

d by Government Exhibit 606 and by testimony that corroborates private information inside the address book. EFTA00105580 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by e-mail) EFTA00105581

ing juror sympathy."). Any attempt to encourage such sympathy is therefore an attempt at nullification, which is itself plainly improper. See, e.g., United States v. Thomas, 116 F.3d 606, 615 (2d Cir. 1997) (Jury nullification is "by no means a right or 3 Evidence of the defendant's motive may be relevant evid

nt. THE GOVERNMENT'S MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY OF DR. PARK DIETZ AND DR. ELIZABETH LOFTUS DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys

forth below, the subpoena should be quashed.' I. Applicable Law As the defendant acknowledges, she bears the burden of satisfying the standard in United States v. Nixon, 418 U.S. 683 (1974). (Def. Mot. at 1). Pursuant to that standard, the "party seeking issuance of [a Rule 17(c)] subpoena must clear three

d by Nixon. 418 U.S. at 700. III. Conclusion For the foregoing reasons, the Court should quash the defendant's subpoena.? Respectfully submitted, DAMIAN WILLIAMS United States Attorney by: as/ Assistant United States Attorneys cc: Counsel of Record (by email) 7 In the event the Court does not quash the s