Epstein Secrets

guage of the statute charged,'" her motion should be denied. United States v. Mingio,209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See

pseudonyms, 153 EFTA00100120 is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

Th]e Second Circuit routinely upholds the 'on or about' language used to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00100121 1838255, at *1, 4-6 (W.D.N.Y

uage of the statute charged,'" her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See

pseudonyms, 153 EFTA00077785 is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

Th]e Second Circuit routinely upholds the 'on or about' language used to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00077786 1838255, at *1, 4-6 (W.D.N.

uage of the statute charged,'" her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See

pseudonyms, 153 EFTA00039600 is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

Th]e Second Circuit routinely upholds the 'on or about' language used to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00039601 1838255, at *1, 4-6 (W.D.N.

guage of the statute charged,' her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). 152 EFTA00095244 First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of

dictment referred to victims by pseudonyms, is particularly instructive here. See id. at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

Th]e Second Circuit routinely upholds the 'on or about' language used to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, 13 Cr. 128 (MA) (HKS), 2014 WL 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying

uage of the statute charged,'" her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See

pseudonyms, 153 EFTA00103178 is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

Th]e Second Circuit routinely upholds the 'on or about' language used to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00103179 1838255, at *1, 4-6 (W.D.N.

34 to describe the window of when a violation occurred." United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019) (quoting United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)). "This is especially true in cases of sexual abuse of children: allegations of sexual abuse of underage victim

of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged

34 to describe the window of when a violation occurred." United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019) (quoting United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)). "This is especially true in cases of sexual abuse of children: allegations of sexual abuse of underage victim

of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged

nt's deficiencies, e.g., lack of names and dates, through citation to obviously inapplicable cases. "First," the government offers United States v. Stringer, 730 F.3d 120, 124 (2d Cir. 2013), for the proposition that "the use of pseudonyms to refer to minor victims of the charged conduct does not warran

386 F. Supp. 3d 364, 369, is incomplete. The court in Kidd explains the range it is referring to by the following reference: "See United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987) (holding that 'on or about June 1984' put a defendant on notice for potential crimes in July or early August of

34 to describe the window of when a violation occurred." United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019) (quoting United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)). "This is especially true in cases of sexual abuse of children: allegations of sexual abuse of underage victim

Filed 04/16/21 Page 21 of 34 Moreover, the Government has agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties to negotiate and propose a full schedule for all remaining pretrial disclos