Epstein Secrets

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

t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.

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

t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.

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

t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.

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

rt that the defendant "had not engaged in any business activity during the preceding six years").54 Accordingly, and consistent with the holding in Ruiz and Broccolo, this Court should deny the severance motion. 54 While the defendant may argue that the fact that her deposition, unlike Ruiz, did not involve crim

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

t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.