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came and found the old car in the driveway? 19 20 A. Exactly, yes, with the police, yes. 20 21 Q. How did you remember that it was Tony 21 22 Figueroa? 22 23 A. It's the only person, male that I 23 24 remember. 24 25 Q. But you don't know his name? 25 Page 445 alrie, I guess. was to help
t were referred to as masseuses, did that also give you access to the girls that were coming over to Mr. Epstein's house in Paris and New York and New Mexico? MR. CRITTON: Form. THE WITNESS: We used to have a book in every car, in every plane, in every boat that Mr. Epstein with all the names of all t
o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 11 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
th, 2002, which only further substantiates Ms. testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in
Florida, and we'll be asking either to cover that through an expert witness or through a jury instruction. But they say, oh, what if she's flown to New Mexico? The age of consent there might be different. And this is where I believe your Honor can take a close look at the expert witness on sex trafficking
which only further substantiates Ms. Giuffre's testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in t
Florida, and we'll be asking either to cover that through an expert witness or through a jury instruction. But they say, oh, what if she's flown to New Mexico? The age of consent there might be different. And this is where I believe your Honor can take a close look at the expert witness on sex trafficking,
o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa, 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
Page: EFTA02857524_p7 →uncovered Epstein's activity with young girls dating back several years. In the early 1990's, Epstein flew a young high school girl to his ranch in New Mexico. Epstein and Ghislaine Maxwell (mentioned above) fondled the girl and encouraged her to engage in additional sexual activity, which she refused. The
Page: EFTA02857524_p73 →Entities connected to both Figueroa and New Mexico

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Bradley Edwards
PERSON
George W. Bush
PERSON
New York
LOCATIONJane Doe
PERSON
Prince Andrew
PERSON
Palm Beach
LOCATION
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Marc Rich
PERSONLeon Black
PERSON
Donald Trump
PERSONMaria Farmer
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSON
Scarlett Johansson
PERSON
Colorado
LOCATION