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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
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards requires the jury to determine whe
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
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards requires the jury to determine whe
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
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards requires the jury to determine whe
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
influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was 121 EFTA00095213 addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards require the jury to determine whet
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
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards requires the jury to determine whe
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
Page: EFTA00029560 →as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
Page: EFTA00029561 →most extraordinary circumstances justify departure from this general rule. United States v. Forde, 740 F. Supp. 2d 406, 412 (S.D.N.Y. 2010) (citing Gaudin, 515 U.S. at 522-23). The charged statements do not fall within this narrow exception. Maxwell contends that the questions did not relate to the se
Page: EFTA00029562 →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
Page: EFTA00020281 →as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
Page: EFTA00020282 →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
Page: EFTA00022111 →as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
Page: EFTA00022112 →Entities connected to both Stringer and Gaudin

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONThompson
PERSON
Medina
PERSONSampson
PERSONMarkiewicz
PERSONForde
ORGANIZATION
Supreme Court
ORGANIZATIONWerner
PERSONChacko
PERSONNejad
PERSON
Napolitano
PERSONMostafa
PERSONConcepcion
PERSONNersesian
PERSONTramunti
PERSON
Murray
PERSONSalameh
PERSONthe Southern District
LOCATION