Epstein Secrets

nited States v. Boustani, 932 F.3d 79 (2d Or. 2019) 6, 25, 26 United States v. Chen, 820 F. Supp. 1205, 1209 (N.D. Cal. 1992) 15 United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012 (S.D.N.Y. July 19, 2013) 16, 19 United States v. Cirillo, No. 99-1514, 1999 WL 1456536 (3d Cir. July 13, 199

o United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *2 (S.D.N.Y. July 19, 2013) ("Because France refuses to extradite its citizens, Cilins can avoid prosecution on this Indictment if he can reach French soil."). In other words, even assuming the Government could locate the defendant, i

fendant. x THE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE AUDREY STRAUSS Acting United States Attorney Southern District of New York Attorney for the United States of America Assistant nueStates Attorneys - Of Counsel - EFTA00103380 TABLE OF CONTENTS THE GOVERNME

nship), including to the United States, and has never derogated from that principle outside the European Union. See Ex. C; see also United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL "taken a number of surprising turns," including the "suppression of video evidence, the indeterminate stay of procee

llo did not mention in its opinion"). 16 EFTA00089170 3802012, at *2 (S.D.N.Y. July 19, 2013) ("Because France refuses to extradite its citizens, Cilins can avoid prosecution on this Indictment if he can reach French soil."). In other words, even assuming the Government could locate the defendant, i

fendant. x THE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE AUDREY STRAUSS Acting United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00089154 UNITED STATES DISTRICT COUR

lar). "Evidence should be excluded on a motion in limine only when the evidence is clearly inadmissible on all potential grounds." United States v. Cilins, No. 13 CR. 315 (WHP), 2014 WL 173414, at *2 (S.D.N.Y. Jan. 15, 2014) (citation and internal quotation marks omitted). B. Discussion The defense's

Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00088802 Table of Contents PRELI