Epstein Secrets

to consider it. A. Applicable Law Relevant evidence is "not confined to that which directly establishes an element of the crime." United States v. Gonzalez, 110 F.3d 941, 942 (2d Cir. 1997). As the Second Circuit has explained, "(t]o be relevant, evidence need only tend to prove the government's case, a

that "the defense will receive notice of any co-conspirator statements that the Government may seek to introduce through witness statements" in its Jencks Act production. (Gov't Opp. at 192, Dkt. No. 204). The Court denied the motion, explaining that the Court lacked the power to order pretrial discl

the moving dekndant. See, e.g., United States I Gonzales-Claudio, 806 F.2d 334, 341 (2d Cir. 1986)("deten

on probable cause, the court commonly will schedule a consolidated preliminary and detention hearing at which the prosecution must make available "Jencks" statements. If a hup://10.173.2.12/usao/cousa/olc/usaboolddrug/26drug.lum 4/10/2008 EFTA00191628 Federal Narcotics Prosecutions - Chapter 26 P

s "list"). The transcript of her interview with the Palm Beach Police over a year before the FRI became involved in any investigation shows that Ms. Gonzalez admitted to lying about her age. that she did not engage in sexual intercourse with Mr. Epstein, and that she was never induced over the telephone.

nts, their credibility and the foundations, if any, for claiming person! injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the tbnn of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the

n. Feinstein). *2 Td. at $4263 (statement of Sen. Feinstein). 3 Td. at S4260 (statement of Sen. Kyl); see also Prepared Remarks of Attorney General Alberto R. Gonzales, Hoover Inst. Bd. of Overseers Conference (Feb. 28, 2005) (indicating a federal victims' rights amendment remains a priority for President Bush). 4

might aid in impeaching government witnesses at trial, "the legislative history expresses a much greater concern with limiting the application of the Jencks decision so that it would not hamper the workings of law enforcement by forcing wholesale disclosure of government materials and files." 33° The Jen