impeachment information because "[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by

: Frida , December 20, 2019 1:56 PM > To: (USANYS) <MINIMIIM>; (USANYS) > Subject: RE: Nycha > Let me know if you have two minutes to talk about the Epstein Fund. Also around Monday if that's better. > Original Messa e---- > From: (USANYS) <MINIMIIN> > Sent: Friday, December 20, 2019 1:42 PM EFTA00031584

667, 684, (1985). Full and complete cross-examination of the Accusers is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Ms. Maxwell, as well as others. Cf. Moore v. Marr, 254 F.3d 1235, 1244 (10th Cir. 2001) (noting that witnesses' "a

impeachment information because "[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by

667, 684, (1985). Full and complete cross-examination of the Accusers is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Ms. Maxwell, as well as others. Cf. Moore v. Marr, 254 F.3d 1235, 1244 (10th Cir. 2001) (noting that witnesses' "a

10, 2020 Page 2 entities that participated in, facilitated, or covered up Jeffrey Epstein's crimes. I understand that, after I raised this issue, the Epstein Fund has now offered to remove those broad releases from its protocol. That is a positive step, but the commitment must be made binding. Third, the Epst

10, 2020 Page 2 entities that participated in, facilitated, or covered up Jeffrey Epstein's crimes. I understand that, after I raised this issue, the Epstein Fund has now offered to remove those broad releases from its protocol. That is a positive step, but the commitment must be made binding. Third, the Epst