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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.
n. Chief Judge McMahon subsequently inquired about the Government's application in two transcribed ex parte and sealed hearings. (Def. Mot. 3, Exs. D & E). At the first hearing, on March 26, 2019, Chief Judge McMahon inquired as to why Boies Schiller did not make an application for permission to be re
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,
on. Chief Judge McMahon subsequently inquired about the Government's application in two transcribed ex pane and sealed hearings. (Def. Mot. 3, Exs. D & E). At the first hearing, on March 26, 2019, Chief Judge McMahon inquired as to why Boies Schiller did not make an application for permission to be re
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,
on. Chief Judge McMahon subsequently inquired about the Government's application in two transcribed ex pane and sealed hearings. (Def. Mot. 3, Exs. D & E). At the first hearing, on March 26, 2019, Chief Judge McMahon inquired as to why Boies Schiller did not make an application for permission to be re
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
on. Chief Judge McMahon subsequently inquired about the Government's application in two transcribed er pane and sealed hearings. (Def. Mot. 3, Exs. D & E). At the first hearing, on March 26, 2019, Chief Judge McMahon inquired as to why Boies Schiller did not make an application for permission to be re
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
on. Chief Judge McMahon subsequently inquired about the Government's application in two transcribed ex pane and sealed hearings. (Def. Mot. 3, Exs. D & E). At the first hearing, on March 26, 2019, Chief Judge McMahon inquired as to why Boies Schiller did not make an application for permission to be re
Entities connected to both Birney and D & E

Jeffrey Epstein
PERSONSalameh
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Jennifer Lopez
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LOCATIONLovasco
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Michael Jackson
PERSONMaria Farmer
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Ghislaine Maxwell
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George W. Bush
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Hernandez
PERSONMichael Casey
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Cornell University
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Kaplan
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Scarlett Johansson
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Julie K. Brown
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