Epstein Secrets

eview of the docket, unfortunately, reflects over one-thousand entries. The parties disagreed about the scope and meaning of virtually all of Judge Sweet's discovery orders, including those related to Ms. Maxwell's depositions. Significantly, Judge Sweet's Order prefaced all the listed categories with

also United States v. Bonacorsa, 528 F.2d 1218, 1221 (2d Cir. 1976). "Precise questioning is imperative as a predicate for the offense of perjury." Bronston v. United States, 409 U.S. 352, 362 (1973). "A question is fundamentally ambiguous when it is not a phrase with a meaning about which men of ordina

2012), is instructive: Succinctly, the prosecutor did not fulfill her obligation to "pin the witness down to the specific object of [her] inquiry." Bronston, 409 U.S. at 360. Any number of straightforward follow-up questions could have clarified the object of inquiry. For example, in addition to the "at

6 III. The Questions and Answers Were Immaterial 10 CONCLUSION 10 Certificate of Service 12 i EFTA00097379 TABLE OF AUTHORITIES Cases Bronston v. United States, 409 U.S. 352 (1973) 6, 7, 10 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 1 United States v. Bonacorsa, 528 F.2d 1218 (2d C

ome provisions and adding language that confidential material could be disclosed to law enforcement. (Def. Mot. 3, Ex. B). On March 18, 2016, Judge Sweet entered a protective order governing the discovery and dissemination of confidential information after the parties agreed to the form of the order o

Boyd v. United States, 116 U.S. 616 (1886) 145 Branzburg v. Hayes, 408 U.S. 665 (1972) 110 Bridges v. United States, 346 U.S. 209 (1953) 53 Bronston v. United States, 409 U.S. 352 (1973) 181 Bryson v. United States, 396 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 C

y 29, 2016 Meeting Exhibit 6: November 30, 2018 Email Exhibit 7: December 6, 2018 Email Exhibit 8: February 28, 2019 Government Letter to Judge Sweet Exhibit 9: February 28, 2019 Government Letter to Judge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of Jul

Boyd v. United States, 116 U.S. 616 (1886) 145 Branzburg v. Hayes, 408 U.S. 665 (1972) 110 Bridges v. United States, 346 U.S. 209 (1953) 53 Bronston v. United States, 409 U.S. 352 (1973) 181 Bryson v. United States, 396 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 C

a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t

or can a conviction rest on answers that are literally true but unresponsive, and therefore "arguably misleading by negative implication." Id.; see Bronston v. United States, 409 U.S. 352, 362 (1973). But when "the answer is false, the fact that it is unresponsive is immaterial." United States v. Corr, 5

y 29, 2016 Meeting Exhibit 6: November 30, 2018 Email Exhibit 7: December 6, 2018 Email Exhibit 8: February 28, 2019 Government Letter to Judge Sweet Exhibit 9: February 28, 2019 Government Letter to Judge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of Jul

Boyd v. United States, 116 U.S. 616 (1886) 145 Branzburg v. Hayes, 408 U.S. 665 (1972) 110 Bridges v. United States, 346 U.S. 209 (1953) 53 Bronston v. United States, 409 U.S. 352 (1973) 181 Bryson v. United States, 396 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 C

a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t

or can a conviction rest on answers that are literally true but unresponsive, and therefore "arguably misleading by negative implication." Id.; see Bronston v. United States, 409 U.S. 352, 362 (1973). But when "the answer is false, the fact that it is unresponsive is immaterial." United States v. Corr, 5

me provisions and adding language that confidential material could be disclosed to law enforcement. (Def. Mot. 3, Ex. B).31 On March 18, 2016, Judge Sweet entered a protective order governing the discovery and dissemination of confidential information after the parties agreed to the form of the order o

ates, 116 U.S. 616 (1886) 101 iv EFTA00095071 Branzburg v. Hayes, 408 U.S. 665 (1972) 78 Bridges v. United States, 346 U.S. 209 (1953) 38 Bronston v. United States, 409 U.S. 352 (1973) 121 Bryson v. United States, 396 U.S. 64 (1969) 101 Burgess v. United States, 552 U.S. 124 (2008) 37 C

a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t

or can a conviction rest on answers that are literally true but unresponsive, and therefore "arguably misleading by negative implication." Id.; see Bronston v. United States, 409 U.S. 352, 362 (1973). But when "the answer is false, the fact that it is unresponsive is immaterial." United States v. Corr, 5

y 29, 2016 Meeting Exhibit 6: November 30, 2018 Email Exhibit 7: December 6, 2018 Email Exhibit 8: February 28, 2019 Government Letter to Judge Sweet Exhibit 9: February 28, 2019 Government Letter to Judge Netbum Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of July

Boyd v. United States, 116 U.S. 616 (1886) 145 Branzburg v. Hayes, 408 U.S. 665 (1972) 110 Bridges v. United States, 346 U.S. 209 (1953) 53 Bronston v. United States, 409 U.S. 352 (1973) 181 Bryson v. United States, 396 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 C

a were the defendant's denials of various sexual activities, not honest answers that would have been quite different. In part for that reason, Judge Sweet authorized the deposition at the outset. Second, the Government was not a party to the civil unsealing litigation and did not have an opportunity t

or can a conviction rest on answers that are literally true but unresponsive, and therefore "arguably misleading by negative implication." Id.; see Bronston v. United States, 409 U.S. 352, 362 (1973). But when "the answer is false, the fact that it is unresponsive is immaterial." United States v. Corr, 5