Epstein Secrets

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

f 'd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 8 United States v. Carboni, 204 F.3d 39 (2d Cir. 2000) 6 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 6 United States v. Cummings, 60 F. Supp. 3d 434 (S.D.N.Y. 2014) vacated on other grounds 858 F.3d 763 (2d Cir. 2017

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

f 'd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 8 United States v. Carboni, 204 F.3d 39 (2d Cir. 2000) 6 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 6 United States v. Cummings, 60 F. Supp. 3d 434 (S.D.N.Y. 2014) vacated on other grounds 858 F.3d 763 (2d Cir. 2017

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

ment." United States v. Townsend, 44 EFTA00088846 No. Si 06 Cr. 34 (JFK), 2007 WL 1288597, at ■1 (S.D.N.Y. May I, 2007) (citing United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992)); United States v. Van Putten, No. 04 Cr. 803 (PKL), 2005 WL 612723, at *3 (S.D.N.Y. Mar. 15, 2005) (similar). As

endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective

f the alleged conspiracy ... is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to 'other crimes, wrongs, or ads' evidence, under which

endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective

of the alleged conspiracy . is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which

endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective

of the alleged conspiracy . is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which

motion takes issue with the Indictment's reference to these sex acts as "abuse" because, the assert, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim-3 subjectively experienced these

of the alleged conspiracy . is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which

endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective

f the alleged conspiracy ... is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which