Epstein Secrets

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 "

uary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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 "

ary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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 "

ary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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 "

ary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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 "

ary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 247, 249 United States v. Sampson, 385 F.3d 183 (2d Cr. 2004) 208 United States v. Sampson, 898 F.3d 270 (2d Cr. 2018) 200, 201 United States v. Sampson, 898 F.3d 287 (2d Cir.

a. ng 68 b. a 70 EFTA00099942 c. Chief Judge McMahoni Memorandum and Order 71 7. rder 74 8. Unsealing of Maxwell's Depositions. 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl

5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 247, 249 United States v. Sampson, 385 F.3d 183 (2d Cir. 2004) 208 United States v. Sampson, 898 F.3d 270 (2d Cir. 2018) 200, 201 United States v. Sampson, 898 F.3d 287 (2d Cir

TA00077607 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge Netbum's Order 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl

5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 247, 249 United States v. Sampson, 385 F.3d 183 (2d Cir. 2004) 208 United States v. Sampson, 898 F.3d 270 (2d Cir. 2018) 200, 201 United States v. Sampson, 898 F.3d 287 (2d Cir

TA00039422 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge Netbum's Order 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl

A00095086 United States v. Salerno, 481 U.S. 739 (1987) 104 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 163, 164 United States v. Sampson, 385 F.3d 183 (2d Cir. 2004) 140 United States v. Sampson, 898 F.3d 270 (2d Cir. 2018) 135, 136 United States v. Sampson, 898 F.3d 287 (2d Cir

8 b. April ', 70 EFTA00095068 c. Chief Judge McMahon's Memorandum and Order 71 7. &OAS% 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl

5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 247, 249 United States v. Sampson, 385 F.3d 183 (2d Cir. 2004) 208 United States v. Sampson, 898 F.3d 270 (2d Cir. 2018) 200, 201 United States v. Sampson, 898 F.3d 287 (2d Cir

TA00103000 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge Netbum's Order 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl