Epstein Secrets

.' Id.11111, 17. All of the overt acts allegedly occurred at unspecified times "between in or about 1994 and in or about 1997" in New York, Florida, New Mexico, and London, England. Id. Counts Two and Four charge Ms. Maxwell with substantive violations of 18 U.S.C. §§ 2422 and 2423(a). Id. 911 13, 19. Coun

ause "substantial prejudice." United States v. Ramos, No. 06 Cr. 172 (LTS), 2009 WL 1619912, at *1 (S.D.N.Y. Jun. 5, 2009) (citing United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004)). The prejudice must be "sufficiently severe to outweigh the judicial economy that would be realized by avoiding

United States v. United States v. United States v. United States v. Randazzo, 80 F.3d 623 (1st Cir. 1996) Rivera, 546 F.3d 245 (2d Cir. 2008) Sampson, 385 F.3d 183 (2d Cir. 2004) Turoff, 853 F.2d 1037 (2d Cir.1988) Walker, 142 F.3d 103 (2d Cir. 1998) Werner, 620 F.2d 922 (2d Cir. 1980) Winchest

d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu

ury is best equipped 119 EFTA00100086 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287,307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude,

14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "

d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu

ury is best equipped 119 EFTA00077751 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude

14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "

d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu

ury is best equipped 119 EFTA00039566 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude

14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "

d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 11 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu

jury is best equipped to determine the meaning that a defendant 119 EFTA00095211 assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).48 An exception arises when language in a question is "fundamentally ambiguous," that is "when it is not a phrase

o prevail" on a Rule 14 motion, 139 EFTA00095231 "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "

d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu

ury is best equipped 119 EFTA00103144 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude

14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "