Epstein Secrets

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys 212 EFTA00103237

as "'an impermissible attempt to compel the Government to provide the 176 EFTA00103201 evidentiary details of its case' (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it

r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: /s Assistant United States Attorneys (212) 637-2225 212 EFTA00100179

s "'an impermissible attempt to compel the Government to provide the 176 EFTA00100143 evidentiary details of its case"' (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it

r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00077844

as "'an impermissible attempt to compel the Government to provide the 176 EFTA00077808 evidentiary details of its case' (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it

r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00039659

as "'an impermissible attempt to compel the Government to provide the 176 EFTA00039623 evidentiary details of its case' (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it

r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 211 EFTA00095303

r was not focused on the construction of the qualified wheel, different "relevant jury pools" have been used by the Second Circuit. Most notably, in Biaggi, the main thrust of the defendant's fair cross-section claim was that reliance on voter registration lists systemically excluded African-Americans

particulars request as "'an impermissible attempt to compel the Government to provide the evidentiary details of its case" (quoting United States v. Biaggi, 675 F. Supp. 790, 810 (S.D.N.Y. 1987)). A bill of particulars should not be misused to compel the Government to disclose "the manner in which it

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d

ICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 31 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 163, 164 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 176 United States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 205, 208 ix EFTA00095076 United States v. Bin Lad