Epstein Secrets

prosecution intentionally caused the delay to gain a tactical advantage over the defendant or "for some other bad faith purpose." United States v. Crouch, 84 F.3 d 1497, 1509, 1512 (5th Cir. 1996). The defendant also cites that several Circuit courts, namely the Fourth, Seventh, and Ninth Circuits, r

er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified pos &WadiDef. Mem. 3, Ex. E at 2-3). The U

11) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 268 United States v. Davis, 702 F.2d 418 (2d Ci

er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through

11) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 268 United States v. Davis, 702 F.2d 418 (2d Ci

er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through

1 United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 40, 41 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 106 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 52 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 176 United States v. Davis, 702 F.2d 418 (2d Ci

e Department reports. Although AUSA-1 does not now recall the attorneys providing her with any 65 EFTA00095157 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at

1) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y. 2010) 268 United States v. Davis, 702 F.2d 418 (2d Ci

er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through