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ause "substantial prejudice." United States v. Ramos, No. 06 Cr. 172 (LTS), 2009 WL 1619912, at *1 (S.D.N.Y. Jun. 5, 2009) (citing United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004)). The prejudice must be "sufficiently severe to outweigh the judicial economy that would be realized by avoiding
United States v. United States v. United States v. United States v. Randazzo, 80 F.3d 623 (1st Cir. 1996) Rivera, 546 F.3d 245 (2d Cir. 2008) Sampson, 385 F.3d 183 (2d Cir. 2004) Turoff, 853 F.2d 1037 (2d Cir.1988) Walker, 142 F.3d 103 (2d Cir. 1998) Werner, 620 F.2d 922 (2d Cir. 1980) Winchest
ted to and appropriately joined with underlying 7 EFTA00091885 substantive crimes when the false declarations "concern the substantive offenses." Potamitis, 739 F.2d at 791. Such cases typically involve situations where the defendant was aware that he was being investigated and either lied to the grand
e statements underlying the Perjury Counts therefore do not "concern" the Mann Act Counts and cannot be joined as part of a "common scheme or plan." Potamitis, 739 F.2d at 791. The government makes only a half-hearted, and ineffective, attempt to allege a connection between the Perjury Counts and the Man
ury is best equipped 119 EFTA00100086 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287,307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude,
14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney
r o f "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In Ruiz, the defendant was a New York state senator who founde
ury is best equipped 119 EFTA00077751 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude
14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney
er of "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In Ruiz, the defendant was a New York state senator who founde
ury is best equipped 119 EFTA00039566 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude
14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney
er of "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In Ruiz, the defendant was a New York state senator who founde
jury is best equipped to determine the meaning that a defendant 119 EFTA00095211 assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).48 An exception arises when language in a question is "fundamentally ambiguous," that is "when it is not a phrase
o prevail" on a Rule 14 motion, 139 EFTA00095231 "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney
er of "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In 142 EFTA00095234 Ruiz, the defendant was a New York stat
ury is best equipped 119 EFTA00103144 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude
14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
t, "[t]he contention that there is some inherent prejudice in joining perjury and related counts with substantive charges has been widely rejected." Potamitis, 739 F.2d at 791. And courts routinely hold that there is no prejudice where the evidence in support of the two counts is "interconnected." Blakney
er of "underlying substantive crimes with perjury counts" is appropriate "where, as here, the false declarations concern the substantive offenses." Potamitis, 739 F.2d at 791; see also United States v. Ruiz, 894 F.2d 501 (2d Cir. 1992) (same). In Ruiz, the defendant was a New York state senator who founde
Entities connected to both Sampson and Potamitis

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONWerner
PERSONThompson
PERSON
Supreme Court
ORGANIZATION
Napolitano
PERSON
Scarlett Johansson
PERSONForde
ORGANIZATIONGaudin
PERSONChacko
PERSON
Medina
PERSONMarkiewicz
PERSONNejad
PERSONConcepcion
PERSONMostafa
PERSONthe Southern District
LOCATION
Adriana Ross
PERSON
Southern District of New York
ORGANIZATIONNersesian
PERSON