Epstein Secrets

or to trial."' (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as to identities of unnamed victims of alleged murder conspiracy); United States v. Castro, No. 08 Cr

ged crimes, nor must the Government provide a preview of the evidence or legal theories it intends to present at trial. See, e.g., United States v. Dupigny, 18 Cr. 528 (JMF), 2019 WL 2327697, at *2 (S.D.N.Y. May 30, 2019) (denying motion for bill of particulars and explaining that the defendant "need no

e let us know if you have any questions or would like to discuss the foregoing. Very truly yours, AUDREY STRAUSS Acting United States Attorney for the Southern District of New York By: s/ / / Assistant United States Attorneys 4 EFTA00023913

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 precluding the term "victim" is both unnecessary and impractical. United States v. Dupigny, 18 CR 528, transcript of October 17, 2019, Docket No. 198 at 50. It is appropriate for the government to use the terms as representative of its l

xample, United States v. Kelly, No. 19 CR 286, which is a high publicity trial involving adults testifying about sex abuse as minors, and that's in the Eastern District of New York; United States v. Raniere, No. 18 CR 204, a high-publicity trial involving at least one adult testifying about sex abuse as minor; United States v

ior to trial." (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as to identities of unnamed victims of alleged murder conspiracy); United States v. Castro, No. 08 Cr

ged crimes, nor must the Government provide a preview of the evidence or legal theories it intends to present at trial. See, e.g., United States v. Dupigny, 18 Cr. 528 (JMF), 2019 WL 2327697, at *2 (S.D.N.Y. May 30, 2019) (denying motion for bill of particulars and explaining that the defendant "need no