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argues that "the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s." Dkt. 30. By submis- sion dated July 18, 2019, the Defense ex- plains: "Epstein was given the passport at issue by
release." 18 U.S.C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the `special prov- ince' of the district court." Paulin, 335 F. Supp. 3d at 610. At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant
C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the 'special prov- ince of the district court." United States v. Paulin, 335 F. Supp. 3d 600, 610 (S.D.N.Y. 2018) (quoting United States v. Shaker, 817 F.2d 189, 196 (2d Cir. 1987)). 313 [9] "The rules concerning admi
argues that "the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s." Dkt. 30. By submis- sion dated July 18, 2019, the Defense ex- plains: "Epstein was given the passport at issue by
release." 18 U.S.C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the `special prov- ince' of the district court." Paulin, 335 F. Supp. 3d at 610. At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant
C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the 'special prov- ince of the district court." United States v. Paulin, 335 F. Supp. 3d 600, 610 (S.D.N.Y. 2018) (quoting United States v. Shaker, 817 F.2d 189, 196 (2d Cir. 1987)). 313 [9] "The rules concerning admi
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
ich evidence of prior crimes, wrongs, or acts is admissible for any purpose other than to show a defendant's criminal propensity." United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006) (internal quotation marks omitted). Where the defendant claims her conduct has an innocent explanation, the admiss
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
relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, 165 EFTA00095257 uncharged
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
relevant under Fed. R. Evid. 402." United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996) (internal citation omitted); see also United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006); United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993). Under this approach, uncharged acts are admissible
Entities connected to both United Kingdom and Paulin

Jeffrey Epstein
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Ghislaine Maxwell
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United States
LOCATION
Prince Andrew
PERSON
Julie K. Brown
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George W. Bush
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New York
LOCATION
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATION
Denmark
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Bradley Edwards
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John F. Kennedy
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Michael Jackson
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Marc Rich
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Stephen Hawking
PERSONthe Southern District
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Samantha Power
PERSON
George Mitchell
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Colorado
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Michigan
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