Epstein Secrets

n of the merits of a dispute.” 6 Wright & Miller, Fed. Prac. & Fed. P. § 1488, p. 814 (3d ed. 2010). Jus

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

F. Supp. 2d 1271, 1272 (D. Utah 2006). 478 Black's Law Dictionary 633 (Bryan A. Garner ed., 8th ed. 2004) (defining the adjective "fair"). 479 See Fed. R. Crim. P. 48 advisory committee's note recounting the history of the 1944 adoption. DAVID SCHOEN HOUSE_OVERSIGHT_017695 --- PAGE BREAK --- Page

(9th Cir. 2006); United States v. Degenhardt, 405 F. Supp. 1341, 1343-44 (D. Utah 2005); see also United States v. Turner, 367 F. Supp. 2d 319, 333 (E.D.N.Y. 2005) (reaching same conclusion). *98 Bucklew Memo, supra note 580, app. a, at 299, 302-03. DAVID SCHOEN HOUSE_OVERSIGHT_017711 --- PAGE BREAK --

(S.D.N.Y. 2005) has been a party to lawsuits in the South- ern District of New York, both as a plain- tiff and defendant.

ritable organizations without the knowledge of the Zakat Committee. Jd. Plaintiffs allege “direct donations were re- ceived through NCB facilities to the Red Crescent Committee, [IIRO], and the Mu- waffaq Foundation,” all Defendants in these actions. Ashton Complaint 4570; Burnett Complaint 195. Muwaffaq al

l prosecution of state and local officials). 157 Fed. Bureau of Investigation, U.S. Dep't of Justice, T

onvincing Congress to expand their discretion at the expense of judges' sentencing authority, see United States v. Kupa, 976 F. Supp. 2d 417, 419-27 (E.D.N.Y. 2013) (describing the legislative history and Justice Department lobbying related to federal drug statutes, notably 27 U.S.C. § 841 (2012)). 218 See

1996). 48 Td. at 2-3 (discussing application of Fed. R. Evid. 615). 49 Motion of Marsha and Tom Kight

rious crimes the right to restitution. *°* Reinforcing those laws, the CVRA guarantees that victims have "the right 43 Magistrate Judge Orenstein of the Eastern District of New York, who has written many thoughtful opinions on the CVRA, has taken a contrary position. See Report and Recommendation, United States v. Ingrassis, No.