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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
s set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin 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 Faill
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
s set forth above, she is wrong. The relevant 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin 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 Faill
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
Rioux, 97 F.3d at 657 ("We conclude that the 69 The defense motion references the expert report of an expert witness named Jeffrey O'Neal Martin ("Martin 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. T
Entities connected to both Torres and Martin Aft"

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSONLeon Black
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John F. Kennedy
PERSONPerez
PERSONCollins
PERSON
Bill Richardson
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Louisiana
LOCATIONWalsh
PERSON
Barneys New York
ORGANIZATION
Southern District of New York
ORGANIZATIONGibson
PERSONSecond Circuit
ORGANIZATION
Audrey Strauss
PERSON
Cynthia Nixon
PERSONthe Second Circuit's
ORGANIZATIONGuzman
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