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he] defense and reasonable in light of the circumstances surrounding [the] case,' the request for a witness list should be denied." United States v. Russo, 483 F. Supp. 2d 301, 309 (S.D.N.Y. 2007) (quoting Bejasa, 904 F.2d at 139-40). "Courts in the Second Circuit typically deny motions for the early
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
n" in which the offense occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
he] defense and reasonable in light of the circumstances surrounding [the] case,' the request for a witness list should be denied." United States v. Russo, 483 F. Supp. 2d 301, 309 (S.D.N.Y. 2007) (quoting Bejasa, 904 F.2d at 139-40). "Courts in the Second Circuit typically deny motions for the early
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
n" in which the offense occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
he] defense and reasonable in light of the circumstances surrounding [the] case,' the request for a witness list should be denied." United States v. Russo, 483 F. Supp. 2d 301, 309 (S.D.N.Y. 2007) (quoting Bejasa, 904 F.2d at 139-40). "Courts in the Second Circuit typically deny motions for the early
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
n" in which the offense occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
he] defense and reasonable in light of the circumstances surrounding [the] case,' the request for a witness list should be denied." United States v. Russo, 483 F. Supp. 2d 301, 309 (S.D.N.Y. 2007) (quoting Bejasa, 904 F.2d at 139-40). "Courts in the Second Circuit typically deny motions for the early
nse 199 EFTA00095291 occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
he] defense and reasonable in light of the circumstances surrounding [the] case,' the request for a witness list should be denied." United States v. Russo, 483 F. Supp. 2d 301, 309 (S.D.N.Y. 2007) (quoting Bejasa, 904 F.2d at 139-40). "Courts in the Second Circuit typically deny motions for the early
is faulty. "It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district." Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App'x 22, 26 (2d Cir. 2013) ("[O]ur precedent makes clear that
suant to a plan adopted by the judges of the district and approved by the Judicial Conference of the Second Circuit. Id.; see also United States v. Bahna, 68 F.3d 19, 23 (2d Cir. 1995). The plan for the Southern District has been in place since February 2009. See Amended Plan for the Random Selection
n" in which the offense occurred and she assumes she will ultimately be tried. To the contrary, the Second Circuit has rejected a similar claim. In Bahna, a defendant in the Eastern District of New York was initially convicted at a trial held at the Brooklyn courthouse; after that conviction was vacat
nited States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207,213,214,217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 1 I United States v. Rutkoske, 506 F.3d 1
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusoiy allegations, but it
States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Aviyulallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Balde, 20 Cr. 281 (KPF) 298 United States v. Barlow, 732 F. Supp. 2d I (E.D.N.Y. 2010) 300
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
ited States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Balde, 20 Cr. 281 (KPF) 298 United States v. Barlow, 732 F. Supp. 2d 1 (E.D.N.Y. 2010) 300
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
ited States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Balde, 20 Cr. 281 (KPF) 298 United States v. Barlow, 732 F. Supp. 2d 1 (E.D.N.Y. 2010) 300
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 143 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 139, 142, 143, 145 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 182, 190 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 4, 9 United States v. Rutkoske, 506 F.3d 170
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
nited States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 88 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 113, 114 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Barlow, 732 F. Supp. 2d 1 (E.D.N.Y. 2010) 207, 208, 210 United States v. Barnes, 520 F. Sup
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
ed States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Balde, 20 Cr. 281 (KPF) 298 United States v. Barlow, 732 F. Supp. 2d 1 (E.D.N.Y. 2010) 300
Entities connected to both Russo and Bahna

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONEmmy Taylor
PERSON
Scarlett Johansson
PERSONThompson
PERSONCollins
PERSONAnnabi
PERSONWalker
PERSONTracy
PERSONBortnovsky
PERSON
Southern District of New York
ORGANIZATION
Giglio
PERSON
Alberto Gonzales
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Supreme Court
ORGANIZATIONSantobello
PERSONPerez
PERSON
Eric Holder
PERSON