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nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and o
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and o
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and o
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
ictim-3's experiences in the Indictment "may not be stricken" "regardless of how prejudicial the language is ...." Scarpa, 913 F.2d at 1013 (quoting DePalma, 461 F. Supp. at 797). the Indictment and in this memorandum, the Government has provided extensive detail regarding Minor Victim-3's anticipated
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article") .36 The Article stated, among other things, that defense attorneys representing victims of Epstein and the defendant "urged" the
ant to the charge, then regardless of how prejudicial the language is, it may not be stricken." Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and o
). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Article").35 The Article stated, among other things, that defense attorneys representing victims of Epstein and Maxwell "urged" the USAO-S
Entities connected to both DePalma and the "Daily News Article

Bradley Edwards
PERSON
Jeffrey Epstein
PERSON
Julie K. Brown
PERSON
Southern District of New York
ORGANIZATION
Medina
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Hayes
PERSON
Ghislaine Maxwell
PERSON
Bill Richardson
PERSON
New Haven
LOCATIONMartin Weinberg
PERSONthe Southern District
LOCATION
Minnesota
LOCATIONMason
ORGANIZATION
Adriana Ross
PERSON
Michael Jackson
PERSON
Chris Tucker
PERSON
Kendall Coffey
PERSON
David Boies
PERSON