Epstein Secrets

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

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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

pecial units for sexual assaults crime and victims in hospitals police precincts, and social service agencies). See generally Jennifer G. Long & John Wilkinson, The Benefits of Specialized Prosecution Units in Domestic and Sexual Violence Cases, AEquitas: Strategies Brief, Dec. 2011, at 1, 1 (describing how

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

sentenced to a term of life imprisonment. 3. The indictment concerning the fifth and sixth applicants 17. In 1999 a Federal Grand Jury sitting in the Southern District of New York returned an indictment against Osama bin Laden and twenty other individuals, including the applicants, inter alia alleging various degrees of

e in relation to the ordinary incidents of prison life (Sandin v. Conner, cited above). This will include transfer to a "supermax" security prison (Wilkinson v. Austin 545 US 209 (2005)). In Wilkinson, the court upheld a system which gave notice of the reasons for placement in the supermax prison, an opp