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not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and only rarely is alleged surplusage stricken from an indictment." 159 EFTA00
ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'!
not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and only rarely is alleged surplusage stricken from an indictment." 159 EFTA00
ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'!
y not be stricken." Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and only rarely is alleged surplusage stricken from an indictment." 159 EFTA00
ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant '6 See, e.g., Intl E
Entities connected to both Mulder and unreasonable,36

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Ghislaine Maxwell
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Julie K. Brown
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