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154 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 77,78,81 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998) 226 United States v. Amato, 15 F.3d 230 (2d Cir. 1994)
torneys, and the Government had not submitted any evidence. Id.; see also United States v. Sattar,272 F. Supp. 2d 348,383 (S.D.N.Y. 2003) (applying Aleman, and orderingan evidentiary hearingbased upon the defendant's submission of an affidavit from an attorney with knowledge of the alleged oral agreeme
met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, E
York. (See 15 Civ. 7433 (LAP), Dkt 26 While, as discussed herein, the Government has uncovered evidence of a phone call from one of the attorneys, Stan Pottinger, to AUSA-1 in early May 2016, AUSA-1 has no specific memory of that call, nor did AUSA-1 provide any notes or records of that call to the team worki
54 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 77, 78, 81 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998) 226 United States v. Amato, 15 F.3d 230 (2d Cir. 1994)
rneys, and the Government had not submitted any evidence. Id.; see also United States v. Sattar, 272 F. Supp. 2d 348, 383 (S.D.N.Y. 2003) (applying Aleman, and ordering an evidentiary hearing based upon the defendant's submission of an affidavit from an attorney with knowledge of the alleged oral agree
York. (See 15 Civ. 7433 (LAP), Dkt. 26 While, as discussed herein, the Government has uncovered evidence of a phone call from one of the attorneys, Stan Pottinger, to AUSA-1 in early May 2016, AUSA-1 has no specific memory of that call, nor did AUSA-1 provide any notes or records of that call to the team worki
met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at I).29 At the meeting, Ed
154 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 77, 78, 81 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998) 226 United States v. Amato, 15 F.3d 230 (2d Cir. 1994)
met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 a
York. (See 15 Civ. 7433 (LAP), Dkt. 26 While, as discussed herein, the Government has uncovered evidence of a phone call from one of the attorneys, Stan Pottinger, to AUSA-1 in early May 2016, AUSA-1 has no specific memory of that call, nor did AUSA-1 provide any notes or records of that call to the team worki
154 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 77, 78, 81 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998) 226 United States v. Amato, 15 F.3d 230 (2d Cir. 1994)
York. (See 15 Civ. 7433 (LAP), Dkt. 26 While, as discussed herein, the Government has uncovered evidence of a phone call from one of the attorneys, Stan Pottinger, to AUSA-1 in early May 2016, AUSA-1 has no specific memory of that call, nor did AUSA-1 provide any notes or records of that call to the team worki
met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 a
cord evidence, and the four corners of the agreement itself. That is not a basis for a hearing. As the Second Circuit explained in United States v. Aleman, "a district court need not conduct a hearing every time a defendant summarily accuses the government of failing to live up to an alleged bargain."
urpose of further damaging a sexual 26 While, as discussed herein, the Government has uncovered evidence of a phone call from one of the attorneys, Stan Pottinger, to AUSA-1 in early May 2016, AUSA-1 has no specific memory of that call, nor did AUSA-1 provide any notes or records of that call to the team worki
met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 a
Entities connected to both Aleman and Stan Pottinger

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
David Boies
PERSON
United States
LOCATIONFBI
ORGANIZATIONthe Southern District
LOCATIONAnnabi
PERSONRusso
PERSON
Southern District of New York
ORGANIZATIONEmmy Taylor
PERSONSantobello
PERSON
Supreme Court
ORGANIZATIONSalameh
PERSONSampson
PERSONCollins
PERSON
Hernandez
PERSON
Prince Andrew
PERSONForde
ORGANIZATIONWerner
PERSON