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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
at 1269 (appeal following conviction and partial Rule 29 dismissal) Markiewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F. Supp. 2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). Indeed, the defendant cites no case in which a court has di
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
at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F. Supp. 2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). Indeed, the defendant cites no case in which a court has di
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
at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F. Supp. 2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). Indeed, the defendant cites no case in which a court has di
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
at 1269 (appeal following conviction and partial Rule 29 dismissal) Markiewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F.Supp.2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). The defendant cites no authority in which a court has dismiss
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
at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F. Supp. 2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). Indeed, the defendant cites no case in which a court has di
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 →son v. United States, 520 U.S. 461, 465 (1997). Only the 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. Max
Page: EFTA00020283 →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 →son v. United States, 520 U.S. 461, 465 (1997). Only the 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. Max
Page: EFTA00022113 →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 →son v. United States, 520 U.S. 461, 465 (1997). Only the 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. Max
Page: EFTA00029562 →Entities connected to both Stringer and Forde

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