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a discovery device or a means to compel the government to disclose evidence or witnesses to be offered prior to trial."' (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of parti
Page: EFTA00023911 →or to trial."' (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as to identities of unnamed victims of alleged murder conspiracy); United States v. Castro, No. 08 Cr
Page: EFTA00023911 →e let us know if you have any questions or would like to discuss the foregoing. Very truly yours, AUDREY STRAUSS Acting United States Attorney for the Southern District of New York By: s/ / / Assistant United States Attorneys 4 EFTA00023913
Page: EFTA00023913 →, a discovery device or a means to compel the government to disclose evidence or witnesses to be offered prior to trial." (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of parti
Page: EFTA00030944 →ior to trial." (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as to identities of unnamed victims of alleged murder conspiracy); United States v. Castro, No. 08 Cr
Page: EFTA00030944 →agreed that he would not contest jurisdiction in the Southern District of Florida for any victim who chose to sue him fo
miss, factual adjudication is inappropriate as all facts asserted—or here, reasonably established—by the plaintiff are to be taken as true. Conley v. Gibson, 355 U.S. 41, at 45-46, 78 S. Ct. 99, at 101-102, 2 L.Ed. 2d 80, -1581 at 84.-As such, the court-has given recognition only to those assertions of th
Page: HOUSE_OVERSIGHT_013396 →(S.D.N.Y. 2005) has been a party to lawsuits in the South- ern District of New York, both as a plain- tiff and defendant.
t, “even when the complaint is liberally con- strued, that the plaintiff can prove no set of facts which would entitle him to relief.” Id.; Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957). Federal Rule of Civil Procedure 8(a) requires that a complaint contain “a short and plain stat
Page: HOUSE_OVERSIGHT_017890 →Entities connected to both Gibson and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Donald Trump
PERSON
Audrey Strauss
PERSON
Marc Rich
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
Geoffrey S. Berman
PERSON
Supreme Court
ORGANIZATIONFBI
ORGANIZATIONLeon Black
PERSON
Bill Clinton
PERSON
New Hampshire
LOCATION
Virginia Giuffre
PERSONSecond Circuit
ORGANIZATION
Michigan
LOCATIONMartin Weinberg
PERSON