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nst him if this is 174 EFTA00100141 necessary to the preparation of his defense, and to avo id prejud icial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
Aff."), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S
ainst him if this is 174 EFTA00077806 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
Aft"), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S
ainst him if this is 174 EFTA00039621 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
Aft"), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S
h the defendant committed the crime charged, or a preview of the Government's evidence or legal theories." Mitlof, 165 F. Supp. 2d at 569; see also Torres, 901 F.2d at 234 ("Acquisition of evidentiary detail is not the function of the bill of particulars.' (quoting Hemphill v. United States, 392 F.2d 4
rtin Aft"), which was prepared for the defense in United States v. Balde, 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S
ainst him if this is 174 EFTA00103199 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q
Aff."), which was prepared for the defense in United States v. Balde, No. 20 Cr. 281 (KPF), where a similar motion is currently pending before Judge Failla. The Government is likewise attaching the expert report of Dr. Bernard R. Siskin, which was prepared for the Government in Balde. As detailed Dr. S
Entities connected to both Torres and Failla

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
George W. Bush
PERSONLeon Black
PERSON
John F. Kennedy
PERSONCollins
PERSONPerez
PERSON
Bill Richardson
PERSON
Stephen Hawking
PERSON
Louisiana
LOCATIONthe Southern District
LOCATIONWalsh
PERSON
Barneys New York
ORGANIZATION
Southern District of New York
ORGANIZATIONGibson
PERSONSecond Circuit
ORGANIZATION