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as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00103285 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00103355 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00103320 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00103250 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00104664 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00105675 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00154652 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00085237 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00090506 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
as a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offen
nts made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the s
other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). 13 EFTA00092767 Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 14 of 34 Section 3283
Entities connected to both Gaudin and Mortg

Supreme Court
ORGANIZATION
Medina
PERSON
Napolitano
PERSON
Jeffrey Epstein
PERSON
United States
LOCATIONNejad
PERSONSampson
PERSONForde
ORGANIZATIONThompson
PERSON
Ghislaine Maxwell
PERSONChacko
PERSONWerner
PERSONMarkiewicz
PERSONMostafa
PERSONConcepcion
PERSONNersesian
PERSON
Scarlett Johansson
PERSONSalameh
PERSON
Adriana Ross
PERSONthe Southern District
LOCATION