Epstein Secrets

zier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock v. United Slates, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside the grand jury ro

he Court's earlier finding. The Government also candidly admits that since then "the delay from October 28, 2010 through early March 2011 was due to the United States' efforts to reach [an] amicable resolution of the case . . . .. Gov't Resp. at 46 n.22. 9 The CVRA does not appear to impose specific timelines for v

ring before Epstein and Groff that had nothing to do with the inner workings of the grand jury. There is abundant caselaw to that effect. See, e.g., United States v. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blal

utors must provide evidence that would help victims. Indeed, in one of the cases cited by the Government — United States v. Sacane, 2007 WL 951666 (D. Conn. Mar. 28, 2007) — the Court specifically stated that the victims should not try to obtain relevant information from the courts but instead should ge

apsing from this assignment and the scheduled date which included an overlap with the Martin Luther King holiday, the Victim Witness Coordinator for the United States Attorney's Office, who had previously been in contact with the mother of the victim in this case during the post-arrest pendency of this matter, imm

feuds and leads to wholesale bloodshed," and "public prosecution is supposed to do away with private vengeance." Lawrence M. Friedman, A HISTORY OF AMERICAN LAW 217- 18 (3d ed. 2005). Although the victim has no veto over the prosecutor's choices, the choices that a prosecutor makes will be better informe

or sentencing proceeding the government's understanding of the amount of possible restitution based upon consultation with, inter alia, the victim." D. Conn. L. Crim. R. 32(m). Victims do not know the ins•and•outs of the restitution statutes. Prosecutors should. The Government's pre-plea consultation wit

5-6 (denying a defendant's application for modification of a criminal protective order so he could use certain discovery materials in a FOIA suit); United States v. DeNunzio, --- F. Supp. 3d ---, 2020 WL 1495880, at *2-.3 (D. Mass. March 27, 2020) (denying a defendant's motion to modify two protective orders i

ars to be somewhat sparse— perhaps because few defendants attempt such a maneuver—see United States v. Calderon, 15 Cr. 025, 2017 WL 6453344, at *3 (D. Conn. Dec. I, 2017) (discussing the relative lack of specific guidance in the context of an application to modify protective orders in criminal cases), se

v. Valerio, 9 F. Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, EFTA00030252 --- PAGE BREAK --- Honorable Richard M

Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). This is for very good reason: Any defendant who signs such a purp

Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of International Affairs is

iction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal prosecutor agrees that 'the Government' will dism

ngs in this case or protect the safety of the community, and that any application for bail should be denied. Very truly yours, GEOF REY S. BERMAN United tates Attorney By: Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324 Cc: Martin Weinberg, Esq., and Re

Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of International Affairs is

's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp.2d 32, 41 (D.D.C. 2005) (sa

iction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal prosecutor agrees that 'the Government' will dism

extradition request is pending in Canada and may be subject to withdrawal."); United States v. Stroh, No. 396-CR-139 (AHN), 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000) ("[I]t appears that there is a substantial legal question as to whether any country to which he fled would enforce any waiver of extr

y had enjoyed. Def. Mot. at 11; see also Def. Mot, Ex. A 1114-5. Other letters similarly highlight that the Defendant's family and affective ties in the United States are stronger than was originally presented to the Court in the initial bail hearing. These letters substantiate the Defendant's claim that she has i

v. Vickers, No. 13-CR-128-A, 2014 WL 1838255, at *8 (W.D.N.Y. May 8, 2014); United States v. Sensi, No. 3:08-CR-253 (WWE), 2010 WL 2351484, at *3 (D. Conn. June 7, 2010). The sex trafficking charges are therefore not time-barred. Regardless of whether it was the general five-year limitations period in

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. Tranzunti, 513 F.2d 1087, 1113 (2d Cir. 1975). "Rule 7(f) of the Federal Rules of Criminal Procedure permits a defendant to seek a bill of parti