Epstein Secrets

rategy. !? To date, about thirty states have adopted amendments to their own state constitutions, | which protect a wide range of victims’ rights. ® Payne v. Tennessee, 501 U.S. 808, 834 (1991) (Scalia, J., concurring) (internal quotations omitted). See generally Douglas E. Beloof, Paul G. Cassell & Ste

ght of the conference report on Rule 16, compelling disclosure of witness names before trial appears inconsistent with the federal rules. And even if the Ninth Circuit's approach was valid at the time Armstrong was decided, such an approach is no longer valid in light of the CVRA. Rule 57(b) only provides a basis for

1210 (2d Cir. 1983) 30, 33 iii EFTA00027310 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 5 of 34 United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelull°, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United

oyees who have at other times also allegedly falsified records. The cases Thomas cites do not support a contrary result. In United States v. Biyan, the Ninth Circuit concluded that the government could not limit its discovery obligations to documents located in the district of prosecution since the case came out

.D.N.Y. Aug. 17, 2018) 20, 22 United States v. Moon, 718 F.2d 1210 (2d Cir. 1983) 30, 33 iii EFTA00031266 --- PAGE BREAK --- United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelullo, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United

oyees who have at other times also allegedly falsified records. The cases Thomas cites do not support a contrary result. In United States v. Bryan, the Ninth Circuit concluded that the government could not limit its discovery obligations to documents located in the district of prosecution since the case came out