Epstein Secrets

ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch

as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo

ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch

as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo

ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch

as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo

ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch

as well as the appropriate method of statistical comparison. See Rioux, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo

ment cannot provide "mountains of documents to defense counsel" as a substitute for a bill of particulars where one would otherwise be required, see Bortnovsky, 820 F.2d at 575, the provision of voluminous discovery in combination with some guidance about what is most relevant can vitiate a need for furthe

as well as the appropriate method of statistical comparison. See RiOUX, 97 F.3d at 656. Here, the defendant contends that the relevant jury pool is the White Plains Qualified Wheel. (Def. Mot. 9 at 5-6). The Government believes that the relevant jury pool is the White Plains Master Wheel, but, as set forth belo