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des no assurances—nor could she—that she will not contest the validity and/or voluntariness of such a renunciation once she is actually in France or the United Kingdom. For example, the Government understands that in order to give up one's British citizenship or status, one must be, among other things, "of sound mi
o give up her British citizenship does not mean that she will not fight extradition once in the United Kingdom or that an extradition request to the United Kingdom would be successful. The Government understands from OIA that a defendant's nationality has historically played little to no role in extradition fro
is also unacceptable because the courtroom has been, and will be, in frequent use, just as it was when the parties in this case met all day for the Daubert hearing and pretrial conference on February 4. The Court's calendar is also constantly shifting, meaning that the defense team will have little to n
Accuser-3's testimony. PRELIMINARY STATEMENT The government and the defense agree on at least this much about Accuser-3: I. She was not a minor in the United Kingdom when she alleges that she was sexually abused by Jeffrey Epstein in 1994-1995; 2. She cannot establish that Ms. Maxwell or Jeffrey Epstein ever cau
sed" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00074480 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) 12 Esquivel-Quintana v. Sessions, 137 S. Ct. 1562 (2017) 14 Grunewald v. United State
Accuser-3's testimony. PRELIMINARY STATEMENT The government and the defense agree on at least this much about Accuser-3: I. She was not a minor in the United Kingdom when she alleges that she was sexually abused by Jeffrey Epstein in 1994-1995; 2. She cannot establish that Ms. Maxwell or Jeffrey Epstein ever cau
sed" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00087775 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) 12 Esquivel-Quintana v. Sessions, 137 S. Ct. 1562 (2017) 14 Grunewald v. United State
nduct, which will somehow prejudice the defendant. (Def. Mot. 4 at 13). The Court should not assume that the jury will speculate about principles of United Kingdom law and apply them to this case. The Court will properly instruct the jury on the elements of the offenses charged in the Indictment and the evidenc
e Government has given notice of a qualified expert who will provide reliable and relevant opinions, as required by Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). (See Def. Mot. 3). Second, evidence relating to Minor Victim-3 is admissible both as dir
Entities connected to both United Kingdom and Daubert

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON
George W. Bush
PERSON
New York
LOCATION
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSON
Prince Charles
PERSON
John F. Kennedy
PERSON
Bradley Edwards
PERSON
Michael Cohen
PERSON
Bloomberg L.P.
ORGANIZATION
New Zealand
LOCATION
Joe Biden
PERSON
George Mitchell
PERSONMaria Farmer
PERSON