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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.
records documenting the substance of the call. The Government has not identified any records that suggest AUSA- I ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
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,
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
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,
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
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
who participated in the February 2016 meeting. The Government is producing all identified emails to defense counsel today. 63 EFTA00095155 with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
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
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
Entities connected to both Birney and Pottinger, Edwards

Ghislaine Maxwell
PERSON
United States
LOCATION
Jeffrey Epstein
PERSON
Julie K. Brown
PERSONIntl Tel
ORGANIZATION
David Boies
PERSONMichael Casey
PERSON
Michael Jackson
PERSONMartindell
PERSONLovasco
PERSON
Cornell University
ORGANIZATION
Kaplan
PERSONJoe Recarey
PERSONSnyder
PERSONColleen McMahon
PERSONPeter Skinner
PERSON
Scarlett Johansson
PERSONEstrada
ORGANIZATION
United States Department of Justice
ORGANIZATIONSalameh
PERSON