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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
es v. Bagaric, 706 F.2d 42 (2d Cir. 1983) 6, 7, 8 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), of '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)
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
es v. Bagaric, 706 F.2d 42 (2d Cir. 1983) 6, 7, 8 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), of '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)
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
and at least one timely overt act is committed in furtherance of the conspiracy within the applicable statute of limitations. See United States v. Salmonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75
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
and at least one timely overt act is committed in furtherance of the conspiracy within the applicable statute of limitations. See United States v. Salmonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing Grunwald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75
Entities connected to both United Kingdom and Salmonese

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
New York
LOCATION
John F. Kennedy
PERSON
Stephen Hawking
PERSON
Bradley Edwards
PERSON
Michael Jackson
PERSONthe Southern District
LOCATION
Michael Cohen
PERSON
Colorado
LOCATION
George Mitchell
PERSON
Michigan
LOCATIONDoug Band
PERSON
Denver
LOCATIONJane Doe
PERSONMartin Weinberg
PERSON
Supreme Court
ORGANIZATION