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"necessary to complete the story of the crime on trial." United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012) ("Robinson argued at trial that Jane Doe was his `girlfriend' and that he had no control over her prostitution activities. Evidence that Robinson was in the prostitution business and contro
dicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(b)."); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) ("The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends
case. AUSA-1 also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00077698 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st
10 (2d Cir. 2008) United States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United
case. AUSA-1 also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00039513 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st
10 (2d Cir. 2008) United States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United
dge Netburn's Order On or about April 9, 2019, the Government advised Judge Netburn, who had not yet ruled on the Government's other application in Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN), of Chief Judge McMahon's decision via a pane and sealed letter. (Def. Mot. 3, Ex. 1). Subsequently,
ited States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) 120, 121 United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 6, 18, 22 United States v. Fennell, 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 192, 194 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 167 United States v. Fiumano, No. 14 Cr.
case. AUSA- I also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00103091 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st
10 (2d Cir. 2008) United States v. Farmer, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United
Entities connected to both Jane Doe and Fennell

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Sarah Kellen
PERSONMartin Weinberg
PERSONFBI
ORGANIZATION
Ken Starr
PERSONthe Eleventh Circuit
ORGANIZATION
Julie K. Brown
PERSON