Epstein Secrets

761, 2014 WL 5366107 (S.D.N.Y. Oct. 14, 2014) (Marrero, J.); United States v. Rajaratnam, 753 F. Supp. 2d 317 (S.D.N.Y. 2011) (I lolwell, J.); and United Stales v. McClure, No. CRIM.A. 10-028, 2010 WL 3523030 (E.D. La. Sept. 1, 2010)).) The subpoenas found permissible in Yudung Zhu, in particular, sought a

N.Y. 2008) (Scheindlin, J.), as amended (Feb. 20, 2008)—has suggested applying a different standard, and that standard has generally been rejected. See United States v. Bergstein, 16-CR-746 (PKC), 2017 WL 6887596, at '4 (S.D.N.Y. Dec. 28, 2017) (Castel, J.) ("'iT]he overwhelming majority of district courts in th

with the court reviewing these documents in camera and then disclosing any admissible documents only after the witness testifies. United States v. Cuthbertson, 630 F.2d 139, 145 (3d Cir. 1980) (affirming decision of district court requiring "pretrial production to the court" in order "to avoid unnecessary

forth below, the subpoena should be quashed.' I. Applicable Law As the defendant acknowledges, she bears the burden of satisfying the standard in United States v. Nixon, 418 U.S. 683 (1974). (Def. Mot. at 1). Pursuant to that standard, the "party seeking issuance of [a Rule 17(c)] subpoena must clear three

d be treated identically to the specific requests for them, as discussed above. EFTA00090229 Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For

6, 1998, at BS. 22 Victims' Rights Amendment. Hearing on S.J. Res. 6 Before the S. Judiciary Comm., 105th Cong. 64 (1997) (statement of Janet Reno, U.S. Att'y Gen.). 30 See www.nveap.org (last visted Dec. 30, 2007). 3! For a comprehensive history of victims' efforts to pass a constitutional amendment,

able to reflect the new role of victims throughout the Rules. Moreover, Congress intended the CVRA to be "a formula for success" and a "model for our States." + The only way the federal rules could serve as a model, I argued, was by fully implementing victims’ rights. I then proposed twenty-eight specific

present systems of [*914] criminal justice." 7°? Indeed, 289 75 F.3d 1275, 1283-84 (8th Cir. 1996). 20 [dat £283. 291 Td. (citing United States v. Cuthbertson, 630 F.2d 139, 146 (3d Cir. 1980)). 292 548 A.2d 408, 415 (Vt. 1988). 293 Td. at 413. 294 Td. at 414-15. 295 Iq. 296 Fd. at 415. 297 Weatherford

forth below, the subpoena should be quashed.' I. Applicable Law As the defendant acknowledges, she bears the burden of satisfying the standard in United States v. Nixon, 418 U.S. 683 (1974). (Def. Mot. at 1). Pursuant to that standard, the "party seeking issuance of [a Rule 17(c)] subpoena must clear three

ally to the specific requests for them, as discussed above. EFTA00010124 --- PAGE BREAK --- Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For

BY ECF The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United Stases v. Chislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order o

g subpoena that "call[s] for the production of the entire investigative file and is accurately described as a fishing expedition"); United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980) ("[T]est for enforcement is whether the subpoena constitutes a good faith effort to obtain ident ed evidence rath