Epstein Secrets

ing on her motions to suppress and that it rule on the merits of her arguments before the trial on the non-perjury counts. Respecifidly submitted, Jeffrey S. Pagliuca CC: Counsel of Record EFTA00105931

jury counts. Respecifidly submitted, Jeffrey S. Pagliuca CC: Counsel of Record EFTA00105931

the illegality." See Wong Sun, 371 U.S. at 488. What's more, "the burden of proof on [an] attenuation claim is on the government." United States v. Ghailani, 743 F. Supp. 2d 242, 259 (S.D.N.Y. 2010) (ordering an evidentiary hearing to put the government to its burden of proving attenuation) (citing Unite

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. 123 EFTA

be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv

n J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Haddon. Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East I Oth Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 wvv.hmftaw.com jpogliucatihmflaw.com Re: United States v. Ghisiain

the illegality." See Wong Sun, 371 U.S. at 488. What's more, "the burden of proof on [an] attenuation claim is on the government." United States v. Ghailani, 743 F. Supp. 2d 242, 259 (S.D.N.Y. 2010) (ordering an evidentiary hearing to put the government to its burden of proving attenuation) (citing Unite

rk By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Dear Counsel: The Silvio J. Mono Building One Saint Andrew's Plaz

U.S. 456, 463 (1996) ("[U]nder Rule 16(a)(2), [a defendant] may not examine Government work product in connection with his case."); United States v. Ghailani, 687 F. Supp. 2d 365, 369 (S.D.N.Y. 2010) (concluding that an internal government memorandum fell within Rule 16(a)(2) of the Federal Rules of Crim