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ons during that period.16 was in communication with on at The FBI still has the "Massage for Dummies" book that provided in 2007 in its custody. Juan Alessi. who worked for E stein as detailed in the prior prosecution memo, confirms that Maxwell recruited from her job in Mar-a-Lago to massage Epstein. F
ook that provided in 2007 in its custody. Juan Alessi. who worked for E stein as detailed in the prior
least one act in furtherance of the conspiracy to traffic while in the Southern District of New York. As to substantive sex trafficking offenses, the Second Circuit recently affirmed an SDNY sex trafficking conviction under 18 U.S.C. § 1591 where the minor victim testified that she was in SDNY when the defendan
2004. The evidence that supports the Defendant's conviction of Count Six, the substantive count, also t Five conspiracy conviction. Additionally, Juan Alessi testified that the Defendant approached n a parking lot and that he then saw her at Epstein's Palm Beach residence later that day. Tria ocumentary
t Five conspiracy conviction. Additionally, Juan Alessi testified that the Defendant approached n a park
assessed on its own terms . . . based on the entire record." United States v. Maslin, 356 F.3d 191, 196 (2d Cir. 2004). In assessing the evidence, the Second Circuit applies a burden-shifting framework. The defendant carries the initial burden of making a non-frivolous showing that the two counts in fact charge
than any other evidence that the proponent can obtain through reasonable efforts" is at best disingenuous. Plaintiff has designated the testimony of Juan Alessi, Mr. Rodriguez's predecessor who held that position during the timeframe in which Plaintiff claims to have been held as a "sex slave" by Mr. Epstei
s. Plaintiff has designated the testimony of Juan Alessi, Mr. Rodriguez's predecessor who held that posit
es statement contained in the report) will never be admissible unless there is a separate and independent hearsay exemptions for such statement. As the Second Circuit has clearly held: "It is well established that entries in a police report which result from the officer's own observations and knowledge may be adm
ve come up from time to time in this case and come up 17 through different witnesses. Now the message pads come in in a 18 number of ways. One is Juan Alessi, who is one of the house 19 butlers. He testified that those were the messages for which 20 they recorded -- we showed him the messages. Yes, tha
ads come in in a 18 number of ways. One is Juan Alessi, who is one of the house 19 butlers. He testifi
hat we proposed to the Court about the 18 financial status comes from the very cases that are in the 19 Second Circuit, and that's the words that the Second Circuit 20 and district courts in the Southern District use. And I quote 21 from Tillery: No evidence as to defendant's financial status 22 may be pres
These have come up from time to time in this case and come up through different witnesses. Now the message pads come in in a number of ways. One is Juan Alessi, who is one of the house butlers. He testified that those were the messages for which they recorded -- we showed him the messages. Yes, that's my
ge pads come in in a number of ways. One is Juan Alessi, who is one of the house butlers. He testified t
And they take the Fifth. So there we are. The question is, are we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the
s were then paid two or three hundred dollars for the massage. On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he wXTousemanager, driver and house mai
raveled with Epstein on his private plane I asked Mr. Alessi about the massages that have occurred at Epstein’
o dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a defe
Entities connected to both Juan Alessi and Second Circuit

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
FedEx
ORGANIZATION
NEW YORK NY
LOCATION
United States
LOCATION
Eric Trump
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Alfredo Rodriguez
PERSONJane Doe
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
George W. Bush
PERSON
Donald Trump
PERSONLarry Visoski
PERSONMaria Farmer
PERSONJack Goldberger
PERSON
David Rodgers
PERSON