Epstein Secrets

"United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States' shows an intent to bind all United States Attorney's Offices. Rather, the plea agreement covers only Defendant's liability in the SDFL."). As the S

Cir. Apr. 26, 2002) (summary order) (plea agreement does not bind other districts "even if the plea agreement purports to bind `the Government"' or the "United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States'

r v. United States, 495 U.S. 575 (1990) 56 Thom v. Ashcroft, 369 F.3d 158 (2d Cir. 2004) 47 Toussie v. United States, 397 U.S. 112 (1970) 48 United State v. Nader, 425 F. Supp. 3d 619 (E.D. Va. 2019) passim United States v. Ahmad, 992 F. Supp. 682 (S.D.N.Y. 1998) 166 United States v. Ahmed, No.

e aprima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

.. . 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

ule 16 of making "a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

"United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States' shows an intent to bind all United States Attorney's Offices. Rather, the plea agreement covers only Defendant's liability in the SDFL."). As the S

Cir. Apr. 26, 2002) (summary order) (plea agreement does not bind other districts "even if the plea agreement purports to bind `the Government' or the "United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States'

r v. United States, 495 U.S. 575 (1990) 56 Thom v. Ashcroft, 369 F.3d 158 (2d Cir. 2004) 47 Toussie v. United States, 397 U.S. 112 (1970) 48 United State v. Nader, 425 F. Supp. 3d 619 (E.D. Va. 2019) passim United States v. Ahmed, 992 F. Supp. 682 (S.D.N.Y. 1998) 166 United States v. Ahmed, No.

e a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

"United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States' shows an intent to bind all United States Attorney's Offices. Rather, the plea agreement covers only Defendant's liability in the SDFL."). As the S

Cir. Apr. 26, 2002) (summary order) (plea agreement does not bind other districts "even if the plea agreement purports to bind `the Government' or the "United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States'

r v. United States, 495 U.S. 575 (1990) 56 Thom v. Ashcroft, 369 F.3d 158 (2d Cir. 2004) 47 Toussie v. United States, 397 U.S. 112 (1970) 48 United State v. Nader, 425 F. Supp. 3d 619 (E.D. Va. 2019) passim United States v. Ahmed, 992 F. Supp. 682 (S.D.N.Y. 1998) 166 United States v. Ahmed, No.

e a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

Cir. Apr. 26, 2002) (summary order) (plea agreement does not bind other districts "even if the plea agreement purports to bind `the Government' or the "United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States'

"United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States' shows an intent to bind all United States Attorney's Offices. Rather, the plea agreement covers only Defendant's liability in the SDFL."). As the S

r v. United States, 495 U.S. 575 (1990) 40 Thom v. Ashcroft, 369 F.3d 158 (2d Cir. 2004) 35 Toussie v. United States, 397 U.S. 112 (1970) 35 United State v. Nader, 425 F. Supp. 3d 619 (E.D. Va. 2019) passim United States v. Alzmad, 992 F. Supp. 682 (S.D.N.Y. 1998) 112 United States v. Ahmed, 10

e a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

"United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States' shows an intent to bind all United States Attorney's Offices. Rather, the plea agreement covers only Defendant's liability in the SDFL."). As the S

Cir. Apr. 26, 2002) (summary order) (plea agreement does not bind other districts "even if the plea agreement purports to bind `the Government' or the "United States"); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase `United States'

r v. United States, 495 U.S. 575 (1990) 56 Thom v. Ashcroft, 369 F.3d 158 (2d Cir. 2004) 47 Toussie v. United States, 397 U.S. 112 (1970) 48 United State v. Nader, 425 F. Supp. 3d 619 (E.D. Va. 2019) passim United States v. Ahmed, 992 F. Supp. 682 (S.D.N.Y. 1998) 166 United States v. Ahmed, No.

a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

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

Rule 16 of making "a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

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

Rule 16 of making "a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

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

ule 16 of making "a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

sory allegation that the requested evidence is material.' United States v. Abdalla, 317 F.Supp.3d 786, 790 (S.D.N.Y. 2018) (quoting United States v. Urena, 989 F.Supp.2d 253, 261 (S.D.N.Y. 2013)). Notably, "if the purported defense for which a defendant seeks to compel the production of certain docume

h Request: The NPA, including but limited to communications within the Department of Justice, with counsel for Mr. Epstein, with representatives of the United States Attorney's offices for the Southern and Middle District of Florida or the Northern District of Georgia and/or counsel for the alleged victims. To th