Epstein Secrets

.. . it defines the basic elements of a fair trial largely through the several provisions of the Sixth Amendment."' Cap/in & Drysdale, Chartered v. UnitedStates, 491 U.S. 617, 633 (1989) (citations omitted). 'The right of an accused in a criminal trial to due process is, in essence, the right to a fair oppor

tation omitted). "It has been clear for a generation that 'Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted.'" United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakers v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment right

nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe

guage of the statute charged,'" her motion should be denied. United States v. Mingio,209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See

pseudonyms, 153 EFTA00100120 is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

tation omitted). "It has been clear for a generation that `Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted."' United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakas v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment rights

nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe

uage of the statute charged,'" her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See

pseudonyms, 153 EFTA00077785 is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

tation omitted). "It has been clear for a generation that `Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted."' United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakas v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment rights

nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe

uage of the statute charged,'" her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See

pseudonyms, 153 EFTA00039600 is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

tation omitted). "It has been clear for a generation that `Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted."' United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakas v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment rights

nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe

guage of the statute charged,' her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). 152 EFTA00095244 First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of

dictment referred to victims by pseudonyms, is particularly instructive here. See id. at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

tation omitted). "It has been clear for a generation that `Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted."' United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakas v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment rights

nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe

uage of the statute charged,'" her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See

pseudonyms, 153 EFTA00103178 is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding "that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the c

nt need do little more than to track the language of the statute charged and state the time and place (in approximate terms) of the alleged crime." United States. v. Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975). In addition to dismissal, "Rule 7(f) of the Federal Rules of Criminal Procedure permits a defendan

ictment. The names of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of

of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged

nt need do little more than to track the language of the statute charged and state the time and place (in approximate terms) of the alleged crime." United States. v. Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975). In addition to dismissal, "Rule 7(f) of the Federal Rules of Criminal Procedure permits a defendan

ictment. The names of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of

of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged

nt's deficiencies, e.g., lack of names and dates, through citation to obviously inapplicable cases. "First," the government offers United States v. Stringer, 730 F.3d 120, 124 (2d Cir. 2013), for the proposition that "the use of pseudonyms to refer to minor victims of the charged conduct does not warran

aine Maxwell in Support of Her Motion to Dismiss Counts One through Four of the Superseding Indictment for Lack of Specificity upon the following: U.S. U.S. Attorne 's Office, SDNY s/ Christian R. Everdeli 7 EFTA00028981

nt need do little more than to track the language of the statute charged and state the time and place (in approximate terms) of the alleged crime." United States. v. Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975). In addition to dismissal, "Rule 7(f) of the Federal Rules of Criminal Procedure permits a defendan

Filed 04/16/21 Page 21 of 34 Moreover, the Government has agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties to negotiate and propose a full schedule for all remaining pretrial disclos