3
Shared Docs
3
Same-Page
4 / 3
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.
sale of firearms and "narcotics transactions," are "part and parcel of the charged conduct or sufficiently similar to them); United States v. Mahe, 477 F. Supp. 2d 560, 566 (E.D.N.Y. 2007) (stating that, although the facts between two fraud schemes were "quite similar," the other acts were "a separate, disc
elf pointed out, the characteristics of the modus operandi must be "sufficiently idiosyncratic to permit a fair inference of a pattern's existence." United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984)); see also United States v. Walla, No. 14—CR- 213 (MICE), 2014 WL 3734522, at *13 (S.D.N.Y. July 25, 2014
s v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 13 EFTA00074481 United States v. Garcia, 291 F.3d 127 (2d Cir. 2002) 11 United States v. Mahsffr, 477 F. Supp. 2d 560 (E.D.N.Y. 2007) vacated in part on other grounds 285 Fed. App'x 797 (2d Cir. 2008) 9 United States v. McCallum, 584 F.3d 471 (2d Cir. 200
elf pointed out, the characteristics of the modus operandi must be "sufficiently idiosyncratic to permit a fair inference of a pattern's existence." United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984)); see also United States v. Walla, No. 14—CR- 213 (MICE), 2014 WL 3734522, at *13 (S.D.N.Y. July 25, 2014
s v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 13 EFTA00087776 United States v. Garcia, 291 F.3d 127 (2d Cir. 2002) 11 United States v. Mahsffr, 477 F. Supp. 2d 560 (E.D.N.Y. 2007) vacated in part on other grounds 285 Fed. App'x 797 (2d Cir. 2008) 9 United States v. McCallum, 584 F.3d 471 (2d Cir. 200
Entities connected to both United States and 477 F. Supp

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
John F. Kennedy
PERSON
Southern District of New York
ORGANIZATION
Michael Cohen
PERSON
United Kingdom
LOCATIONGarcia
PERSONJeffrey Pagliuca
PERSON
Jeff Sessions
PERSONCohen & Gresser LLP
ORGANIZATION
Townsend
PERSONThe Second Circuit
ORGANIZATIONMann Act
PERSONR. Everdell
PERSONMORGAN & FOREMAN
ORGANIZATIONConcepcion
PERSONBobbi C. Sternheim
PERSONCummings
PERSON
Figueroa
PERSON