Epstein Secrets

in similarly abusive circumstances at the time of trial, and who gave dishonest answers regarding that subject at voir dire, was impliedly biased); United States v. Eubanks, 591 F.2d 513, 517 (9th Cir. 1979) (per curiam) (implying bias where, in a trial for participation in a heroin distribution conspiracy, a

ere and there is no legal basis for Juror No. 50 to intervene in this matter. This is not a request by a journalist to intervene for public access. See United States v. Aref, 533 F.3d 72, 81 (2d Cir. 2008) (motion to intervene to assert the public's First Amendment right of access to criminal proceedings is prop

otion for a New Trial, with the Court and counsel for the government: U.S. Attorney's Office SDNY One Saint Andrew's Plaza New York. NY 10007 s/ Nicole Simmons 59 EFTA00155966

utweighed by its prejudicial effect; and (4) the trial court gave an appropriate limiting instruction to the jury if so requested by the defendant." United States v. Arroyo, 600 F. App'x II, 13 (2d Cir. 2015) (summary order) (quoting United States v. Lanam, 369 F.3d 153, 156 (2d Cir. 2004). are offered for im

n which apparently relied in reaching her conclusions. This Court should reject the government's untimely effort to save testimony from exclusion. See United States v. Lewis, 818 F. App'x 74, 79 (2d Cir. 2020) (unpublished) (affirming exclusion of defendant's proffered expert evidence "that did not adhere to th

F system which will send notification of such filing to the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York NY 10007 s/ Nicole Simmons 46 EFTA00090772

motion misstated the right-to-access law. To the contrary the Opinion correctly summarized the law, and properly identified the leading cases from the United States Supreme Court and this Court. See, e.g., Sp.App. 16-26. The gravamen of the appellants' argument centered on—and many of the panel's questions were

hrer ([email protected]) Andrew G. Celli ([email protected]) David Lebowitz ([email protected]) Jay M. Wolman ([email protected]) s/ Nicole Simmons 26 EFTA00791895

counsel stated in a phone conversation that Mr. Brunel's counsel said his client had gone to France and it was unclear when he would be returning to the United States. Following the filing of the instant motion, counsel for Ms. Maxwell requested copies of the certificates of service for all of Plaintiff's Rule 45

, Ste. 2 Ft. Lauderdale, FL 33301 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] Id Nicole Simmons Nicole Simmons 26 EFTA00605140

t Salt Lake City, UT 84112 [email protected] Michael C. Miller Justin Y.K. Chu Michael A. Keough STEPTOE & JOHNSON, LLP 1114 Avenue of the Americas New York, NY 10036 [email protected] [email protected] [email protected] Is, Nicole Simmons Nicole Simmons EFTA00794012

l A. Keough STEPTOE & JOHNSON, LLP 1114 Avenue of the Americas New York, NY 10036 [email protected] [email protected] [email protected] Is, Nicole Simmons Nicole Simmons EFTA00794012

e 403 define "undue prejudice" as an "undue tendency to suggest decision on an improper basis, commonly, though not necessarily, an emotional one." See United States v. Salim, 189 F. Supp. 2d 93, 98 (S.D.N.Y. 2002). Here, any probative value of the items is substantially outweighed by the unfair prejudice to Ms

of Court using the CM/ECF system which will send notification of such filing to the following: U.S. Attorney's Office, SDNY New York. NY 10thr d Nicole Simmons 5 EFTA00072837

n abuse of discretion occurs if the district court fails to make the required factual findings, or if those factual findings are clearly erroneous." United States v. Juvenile Male No. 1, 47 F.3d 68,71 (2d Cir. 1995) (citation omitted). B. The district court erred in ordering the unsealing. There are "two rela

ef to: The Hon. Loretta A. Preska District Judge United States District Court for the Southern District of New York (via United States mail) s/ Nicole Simmons 43 EFTA00075525 Case 20-2413, Document 40. 08/20/2020. 2913550. Page50 of 74 Attachment 1 to Opening Brief July 23, 2020 Transcript Ordering Un

l efficiency outweigh the recognized prejudice that accrues to the accused." United States v. Turoff, 853 F.2d 1037, 1042-43 (2d Cir.1988); see also United States v. Werner, 620 F.2d 922, 928 (2d Cir. 1980) (purpose of Rule 8 is to promote "trial convenience and economy of judicial and prosecutorial resources"

system which will send notification of such filing to the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York NY 10(117 s/ Nicole Simmons 15 EFTA00091893

ersity Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] /s/ Nicole Simmons Nicole Simmons HOUSE_OVERSIGHT_014658 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 1 of 9 EXHIBIT A HOUSE_OVERS

ine and Jeffrey left us after that, and later Andrew left. ‘In the morning, Ghislaine said, “You did well. He had fun". We flew straight back to the States.’ The Mail on Sunday has confirmed that the tycoon’s jet flew to Paris on March 6, 2001, continuing to Granada, Tangier and London, before returning