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hat each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor."' Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that the Court can determine now—on a pre- 44 For similar reasons, the defendant's request fordiscovery regarding this matter should be deni
that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that the Court can determine now—on a pre- 44 For similar reasons, the defendant's request for discovery regarding this matter should be den
that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that the Court can determine now—on a pre- 44 For similar reasons, the defendant's request for discovery regarding this matter should be den
that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that that the Court can determine now—on a pre-trial record that is not factually developed—that the questions were fundamentally ambiguous
that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that the Court can determine now—on a pre- 44 For similar reasons, the defendant's request for discovery regarding this matter should be den
Entities connected to both Heath and Counts

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Scarlett Johansson
PERSON
Supreme Court
ORGANIZATION
Chris Tucker
PERSON
Michael Jackson
PERSON
Bradley Edwards
PERSON
George Mitchell
PERSONJane Doe
PERSON
George W. Bush
PERSON
Minnesota
LOCATION
Virginia Giuffre
PERSONDoug Band
PERSONthe Southern District
LOCATION
Bill Richardson
PERSON
Eric Schmidt
PERSON
Kaplan
PERSON
Colorado
LOCATION