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ited States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) 240 United States v. Birney, 686 F.2d 102 (2d Cir. 1982) 61, 65 United States v. Birrell, 470 F.2d 113 (2d Cir. 1972) 183 EFTA00099951 United States v. Blakney, 941 F.
As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unswom assertions as to vague generalities" that witnesses, "if alive, would give testimony
o old, at most the door is barely ajar."). Substantial prejudice is just that—substantial, actual, non-speculative prejudice. See United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982) (a defendant's "proof of prejudice must be definite and not speculative"); see also United States v. Henderson,
As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony
o old, at most the door is barely ajar."). Substantial prejudice is just that—substantial, actual, non-speculative prejudice. See United States v. Birney, 686 F.2d 102, 105-06 (2d Cir. 1982) (a defendant's "proof of prejudice must be definite and not speculative"); see also United States v. Henderson,
As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony
Biaggi, 909 F.2d 662 (2d Cir. 1990) 205, 208 ix EFTA00095076 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) United States v. Birney, 686 F.2d 102 (2d Cir. 1982) United States v. Birrell, 159 43, 45 470 F.2d 113 (2d Cir. 1972) 122 United States v. Blakney, 941 F.2d 114 (2d
As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony
ited States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) 240 United States v. Birney, 686 F.2d 102 (2d Cir. 1982) 61, 65 United States v. Bbrell, 470 F.2d 113 (2d Cir. 1972) 183 EFTA00103009 United States v. Blakney, 941 F.2
As to Epstein's mother, who died in April 2004, the defendant contends that she "would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997." (Def. Mot. 7 at 9). "Counsel's unworn assertions as to vague generalities" that witnesses, "if alive, would give testimony
Entities connected to both Birney and Accusers

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Colorado
LOCATIONMartin Weinberg
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
Cynthia Nixon
PERSONMaria Farmer
PERSON
Department of Justice
ORGANIZATIONWerner
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Burke
PERSON
Julie K. Brown
PERSON
David Boies
PERSONSalameh
PERSON
Jennifer Lopez
PERSON
Cornell University
ORGANIZATIONLovasco
PERSON