Epstein Secrets

H,DAVID H MASHEK,CHANDLER C GOODMAN,MURRAY H POWER,MARIA SCHAR,DWIGHT C T

Y MCINTOSH,HENRY BOOMHOWER,R FIGUEROA,BARBARA GOLDSMITH,GERALD C BAKER,HO

. Discovery responses containing bare-boned objections, without more, are stricken as a matter of course. Id. See also Murray Van & Storage, Inc. v. Murray, 343 So. 2d 61 (Fla. 4th DCA 1977) (stating that an objection to discovery claiming that the sought-after information is not reasonably calculated

ing party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

issue other than on behalf of the client, and it is apparent that the testimony may be prejudicial to the client." N.Y. R.P.C. 3.7(b); see generally Murray v. Met. Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00100116 VII. The Indictment Contain

o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha

issue other than on behalf of the client, and it is apparent that the testimony may be prejudicial to the client." N.Y. R.P.C. 3.7(b); see generally Murray v. Met. Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00077781 VII. The Indictment Contains

o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha

issue other than on behalf of the client, and it is apparent that the testimony may be prejudicial to the client." N.Y. R.P.C. 3.7(b); see generally Murray v. Met. Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00039596 VII. The Indictment Contains

o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha

ller v. Pate, 386 U.S. 1 (1967) 108, 117, 118 Mills v. Scully, 826 F.2d 1192 (2d Cir. 1987) 108 Minnesota v. Murphy, 465 U.S. 420 (1984) 100 Murray v. Met. Life Ins. Co., 583 F.3d 173 (2d Cir. 2009) 149 Nijhawan v. Holder, 557 U.S. 29 (2009) 40 Nix v. Williams, 467 U.S. 431 (1984) 93, 94

tates v. Feldman, 939 F.3d 182 (2d Cir. 2019) 6, 18, 22 United States v. Fennell, 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 192, 194 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 167 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 48 United States v. F

ensive details contained in the Indictment provide the defendant with more than sufficient notice of the charges against her. 3.7(b); see generally Murray v. Met Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00095241 A. Applicable Law It is wel

o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha

. Discovery responses containing bare-boned objections, without more, are stricken as a matter of course. Id. See also Murray Van & Storage, Inc. v. Murray, 343 So. 2d 61 (Fla. 4th DCA 1977) (stating that an objection to discovery claiming that the sought-after information is not reasonably calculated

ing party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

. Discovery responses containing bare-boned objections, without more, are stricken as a matter of course. Id. See also Murray Van & Storage, Inc. v. Murray, 343 So. 2d 61 (Fla. 4th DCA 1977) (stating that an objection to discovery claiming that the sought-after information is not reasonably calculated

ng party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

issue other than on behalf of the client, and it is apparent that the testimony may be prejudicial to the client." N.Y. R.P.C. 3.7(b); see generally Murray v. Met. Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00103174 VII. The Indictment Contains

o have some adverse effect upon a defendant beyond tending to prove the fact or issue that justified its admission into evidence." United States v. Figueroa, 618 F.2d 934, 943 (2d Cir. 1980). Other acts evidence is typically not unfairly prejudicial where it is not "any more sensational or disturbing tha