Epstein Secrets

to materials within prosecutors' possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution.'" (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 742 (S.D.N.Y. 201

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys 212 EFTA00103237

to materials within prosecutors' possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution.' (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 742 (S.D.N.Y. 2018

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: /s Assistant United States Attorneys (212) 637-2225 212 EFTA00100179

to materials within prosecutors' possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution.'" (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 742 (S.D.N.Y. 201

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00077844

to materials within prosecutors' possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution.'" (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 742 (S.D.N.Y. 201

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00039659

to materials within prosecutors' possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution.' quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 742 (S.D.N.Y. 2018)

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 211 EFTA00095303

rio, 540 N.Y.S.2d 615 (N.Y. App. Div. 1989) eccceessccscentsccscseeeecesnseeeseseseeesnseseeesnseseeesnsesceesnsesecesnseeceesnseeeeeanseeceeanseees Strauss v. Credit Lyonnais, S_A., No. CV-06-0702, 2006 U.S. Dist. LEXIS 72649 (E.D.NLY. Oct. 5, 2006) v.cccsseseesseensen Sys. v. Masterson Mktg., No. 11-CV

terrorism, which basic principles of customary international law, a considerable range of judicial decisions, and the determinations of Congress and the Executive Branch all establish as acts that violate international law for purposes of establishing an ATS claim. While plaintiffs perhaps did not adequately allege a