7
Shared Docs
7
Same-Page
8 / 7
Mentions
ense may make arguments attacking the credibility of victims, the Government is free to argue that these witnesses are, in fact, victims of a crime. Cl United States v. Thai, 29 F.3d 785, 807 (2d Cir. 1994) (explaining that prosecutors may also "respond to an argument that impugns its integrity or the integrity
y this form of testimony, as explained above. To the extent Raymond stands for such a broad proposition, it is contrary to the law of this Circuit. See United States v. Joseph, 542 F.3d 13, 21-22 (2d Cir. 2008), abrogated on other grounds as recognized by United States v. Ferguson, 676 F.3d 260, 276 n.14 (2d Cir.
nce of 50 feet under "streetlight illumination" but was familiar with defendant from seeing him previously in neighborhood); accord United States v. Lumpkin, 192 F.3d 280, 288 (2d Cir. 1999) (officers' in-court identifications reliable where officers had unobstructed views of the defendant selling narco
is case does not involve material gathered independently by the SEC, the Public Company Accounting Oversight Board, or the New York Stock Exchange. See United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) ("SEC"); United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.
witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min
is case does not involve material gathered independently by the SEC, the Public Company Accounting Oversight Board, or the New York Stock Exchange. See United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) ("SEC"); United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.
witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min
ing juror sympathy."). Any attempt to encourage such sympathy is therefore an attempt at nullification, which is itself plainly improper. See, e.g., United States v. Thomas, 116 F.3d 606, 615 (2d Cir. 1997) (Jury nullification is "by no means a right or 3 Evidence of the defendant's motive may be relevant evid
29 United States v. Labansat, 94 F.3d 527 (9th Cir. 1996) 26, 30 United States v. Libby, 461 F. Supp. 2d 3 (D.D.C. 2006) passim United States v. Lumpkin, 192 F.3d 280 (2d Cir. 1999) 20,21,22,31 United States v. Mathis, 264 F.3d 321 (3d Cir. 2001) 29 United States v. Moore, 798 F.2d 1308 (5th Cir.
is case does not involve material gathered independently by the SEC, the Public Company Accounting Oversight Board, or the New York Stock Exchange. See United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) ("SEC"); United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.
witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min
is case does not involve material gathered independently by the SEC, the Public Company Accounting Oversight Board, or the New York Stock Exchange. See United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) ("SEC"); United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.
witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min
is case does not involve material gathered independently by the SEC, the Public Company Accounting Oversight Board, or the New York Stock Exchange. See United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) ("SEC"); United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.
witness...." United States v. Teman, No. 19-CR-696 (PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554 (8th Cir. 1975). The Government is the Team In an attempt to min
Entities connected to both United States and Lumpkin

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Prince Andrew
PERSONFBI
ORGANIZATION
Prince Charles
PERSON
New York
LOCATION
Scarlett Johansson
PERSON
Julie K. Brown
PERSONSouthern District
LOCATION
Alfredo Rodriguez
PERSON
Colorado
LOCATION
Denver
LOCATIONCollins
PERSONHaley Robson
PERSON
Brady
PERSONJeffrey Pagliuca
PERSONHaddon
PERSON
Foreman
PERSONthe New York Stock Exchange
ORGANIZATION