EFTA01177413Set 9
2011-01-1869p14,885w
argued
DEBORAH L MORSE
Petu Pork i§uprente Court
Appellate Division - First Department
THE PEOPLE OF THE STATE OF NEW YORK,
Respondent,
- against -
JEFFREY E. EPSTEIN
Dcfendant-Appellant.
BRIEF ... ENTIRELY FAIR AND
PROPER 33
CONCLUSION 63
EFTA01177414
TABLE OF AUTHORITIES
CASES
Contrast People v. Ferguson, 53 A.D.3d 571 (2d Dept. 2008) 57
People v. Belter, 84 A.D.3d ... Dept. 2011) 58
People v. Brensic, 70 N.Y.2d 9 (1987) 43
People v. Conway, 47 A.D.3d 492 (1st Dept. 2008) 36
People v. Guaman, 8 A.D.3d 545 (2d Dept
https://www.justice.gov/epstein/files/DataSet%209/EFTA01177413.pdf
EFTA00722615Set 9
6p3,445w
corroborative evidence "tending to
connect the defendant with the commission" of the crime. People v Griffin (1981, 4th Dept) 83 App Div 2d 180, 443
NYS2d 935.
In a prosecution ... that he owned or leased the premises in question, and
alleged that all the People proved was that defendant was a doorman for the building involved, failure to charge
promoting ... made out, there existed a reasonable view that defendant committed the
lessor included offense. People v Rodriguez (1984, 1st Dept) 104 App Div 2d 547, 480 NYS2d 214.
Defendant, hotel
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722615.pdf
EFTA02009318Set 10
2012-03-0546p11,843w
nuclear program represents a Holocaust-scale threat to the
Jewish state, and the Jewish people, Obama suggested strongly
that historical fears cannot be the sole basis for precipitous
action ... years later, we can look back and say we have been successful
beyond most people's expectations. When we came in, Iran was
united and on the move ... table.' You've probably said it 50 or 100 times. And a lot of
people believe it, but the two main intended audiences, the
supreme leader of Iran
https://www.justice.gov/epstein/files/DataSet%2010/EFTA02009318.pdf
EFTA00020729Set 8
2015-11-2328p10,014w
hiding some of the things that it knows about me and about
other powerful people involved in this case. I am filing this declaration so that the Court will
have ... friends, I
knew that Epstein was connected to some of the most powerful people in the world, including a
member of the British Royal family, a former President ... physical abuse that I suffered when Epstein forced me to
have sex with other people. Without going into the details of the sexual activities I was forced to
endure, there
https://www.justice.gov/epstein/files/DataSet%208/EFTA00020729.pdf
EFTA01737583Set 10
2014-05-2231p8,245w
make the concessions that we want.
EFTA_R1_00024215
EFTA01737585
And then some people in the U.S. Congress and in the media—
who have been skeptical on this all along ... were especially wary of
disengagement are going to say, "You see, all along these
people were for regime change. They didn't want to make a
deal." So they ... This is similar to the
situation here in the United States, where there are people who
fundamentally want regime change in Iran and do not want a
deal because they
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01737583.pdf
EFTA00804723Set 9
64p39,281w
autocrats seek totalitarian control over played an outsized role in the development of
people's everyday lives, movements, or thoughts. modern authoritarian systems. This is particu-
The media are more ... liberal model. Examples of this phenomenon
the public—especially students and young people— include:
around nonpartisan reformist goals and use relatively
open online media to spread their messages. 1. Majoritariankun ... deaths of millions of have offered diplomatic support, loans, fuel, or direct
his own people. In Turkey Erdogan has decreed military aid to the regime of Bashar al-Assad.
that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804723.pdf
EFTA00135712Set 9
2020-10-0142p25,912w
indication - and the inspector
general would say it if he found it - that people were doing bad things on purpose, but that doesn't
make it any less concerning ... from Republicans."
filnnmherg (9/30, Strohm, 4.73M) reports, "Comey said the probe into whether people close
to Donald Trump conspired with Russia to interfere in the 2016 election was largely ... 9/30, Coy, 23K) reports, "Memphis police have reported a staggering
number of young people murdered in 2020. So far this year, 27 children have been killed. Nine of
the cases
https://www.justice.gov/epstein/files/DataSet%209/EFTA00135712.pdf
EFTA00045963Set 9removed from DOJ
2019-08-191000p211,050w
side of a school
bus and a city bus with more than 3o people on board.
4 Narcs nab speed-demon drug dealer as he leaves Bronx
nightclub
A speed ... systemic
issues" at the federal Bureau of Prisons.
How the First Step Act got people out of prison and back with their families
Fs/1'c
On March 11, 2019, Norah ... systemic issues" at the
federal Bureau of Prisons.
• •
How the First Step Act got people out of prison and back with their families
Mic
On March 11, 2019, Norah Yahya
https://www.justice.gov/epstein/files/DataSet%209/EFTA00045963.pdf
EFTA00060822Set 9
2021-08-0552p11,564w
prisoners are to be transferred."
5 : Mm-hmm.
6 : And it's two people's
7 name, and the second one says
8 "Please schedule the transfer for Friday ... right. Great. And
24 the second, the first two people are the same
25 two people that were listed on this other
EFTA00060830
10
1 email. And the second person ... printout of
11 the call out, of whatever this is. This here
12 is people's report (Indiscernible *00:08:22),
13 they print out (Indiscernible *00:08:23) from
https://www.justice.gov/epstein/files/DataSet%209/EFTA00060822.pdf
EFTA00660159Set 9
2012-04-2323p8,110w
Iranians have been militarizing their
nuclear "research." Even so, an astonishing number of intelligent people in
America and Europe appear to believe that Khamenei's fatwa about the
"sinfulness ... from the jihadis, said Yezid Sayigh of the Carnegie
Middle East Center in Beirut.
"People who are local and pious and moving in an Islamist direction and
are taking ... Jordan, Syria, Lebanon, and Egypt. These are the rights of
citizens, the rights of peoples, and the right of the host country. Therefore,
you need these sides. Also some international
https://www.justice.gov/epstein/files/DataSet%209/EFTA00660159.pdf
EFTA00676554Set 9
2014-01-2421p6,966w
were not proceeding at a meaningful pace in
Syria. His response was that the people have to be prepared for structural
reforms and, therefore, he was embarking on "administrative reforms ... deeds. Many observers thought he would get
out ahead of the young Syrian peoples' call for reforms, akin to what
King Mohammed VI of Morocco did. Instead, he listened ... Perhaps it's the altitude. Maybe it's the rich food -- or the
rich people. Or maybe the word for chutzpah in Farsi is "Davos."
For whatever reason, Iranian President
https://www.justice.gov/epstein/files/DataSet%209/EFTA00676554.pdf
EFTA01999617Set 10
2012-04-1428p7,881w
restive
areas. However, talk of the cease-fire "holding" seems highly
misleading, as 26 people were still killed by regime forces Thursday,
according to the London-based Syrian Network ... Beijing—or indeed, Damascus—to accommodate him.
At the last Friends of the Syrian People conference in Istanbul,
Washington announced that it would send more "non-lethal ... Syrian security forces
into a Turkish refugee camp on Sunday, which left several people—
including one Turkish policeman—seriously wounded.
Prime Minister Recep Tayyip Erdogan this week threatened that
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01999617.pdf
EFTA00490547Set 9
2019-02-059p4,075w
conditions. What
they've almost never done is test their drugs on the sickest
people, those on the verge of suicide. There are ethical
considerations: Doctors don't want ... first selective serotonin reuptake
inhibitor, or SSRI, ushered in an era of what people in the
industry call me-too drug development, research that seeks to
improve on existing medicines ... Yale-affiliated VA Connecticut Healthcare System in
West Haven to see how depressed people would react to the drug.
"If we had done the typical thing ... we would have
completely
https://www.justice.gov/epstein/files/DataSet%209/EFTA00490547.pdf
EFTA00774068Set 9
2009-04-184p1,256w
group and give a 1 minute presentation of why their object is interesting. People would enjoy this, and you will
see some fun things, but it is not a competition ... audience to say "cool" or "wow" in as little
time as possible. Again, people would see and hear some fun things.
Got to run to a meeting, will talk later ... this?
Is there a focus?
Do you want some really fun smart people too?
From: Jeeyacation <•eevacation@ mail.wm>
To: Al seckel < >
Sent: Friday, April
https://www.justice.gov/epstein/files/DataSet%209/EFTA00774068.pdf