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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
he defendant invites the Court to engage in a balancing test that weighs the prejudice to the defendant against the Government's reasons for delay. (Del Mot. 7 at 5,6 n.4). This Court should reject the defendant's invitation. The defendant cites United States v. Brand, 556 F.2d 1312, 1317 n.7 (5th Cir.
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
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
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
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
Entities connected to both Accusers and Del Mot

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Colorado
LOCATION
Prince Andrew
PERSONDarren Indyke
PERSONMartin Weinberg
PERSON
Department of Justice
ORGANIZATION
Cynthia Nixon
PERSONWerner
PERSONthe Southern District
LOCATION
George W. Bush
PERSONMaria Farmer
PERSON
Burke
PERSON
David Boies
PERSONthe Second Circuit's
ORGANIZATIONMulder
PERSON
Southern District of New York
ORGANIZATIONSchneider
PERSON
Ken Starr
PERSON