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n doctrine because Plaintiff claims that Defendant engaged in a continuous course of conduct that in- jured her upon each instance of abuse. See Perez v. Laredo Junior Coll., 706 F2d 731, 733 (5th Cir.1983) (noting that if the violation "does not occur at a single moment but in a series of separa
e upset that the photos had been taken without their consent. They asked the Lackawanna County Dis- trict Attorney to conduct a criminal inves- for the Ninth Circuit, sitting by designation. EFTA00226293 DOE I CHAMBERLIN 193 Clteas2119 KM )92 (irdClr. 2002) Sexual Exploitation Act (PCASEA) against photograp
d 04/24/20 Page 5 of 34 United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelull°, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United States v. Persico, 645 F.3d 85 (2d Cir. 2011) 8 21 10 8 United States v. Reese, 933 F. Supp. 2d 579 (S
Page: EFTA00027311 →oyees who have at other times also allegedly falsified records. The cases Thomas cites do not support a contrary result. In United States v. Biyan, the Ninth Circuit concluded that the government could not limit its discovery obligations to documents located in the district of prosecution since the case came out
Page: EFTA00027331 →66 --- PAGE BREAK --- United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelullo, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United States v. Persico, 645 F.3d 85 (2d Cir. 2011) 8 21 10 8 United States v. Reese, 933 F. Supp. 2d 579 (S
Page: EFTA00031267 →oyees who have at other times also allegedly falsified records. The cases Thomas cites do not support a contrary result. In United States v. Bryan, the Ninth Circuit concluded that the government could not limit its discovery obligations to documents located in the district of prosecution since the case came out
Page: EFTA00031287 →Entities connected to both Perez and the Ninth Circuit

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Donald Trump
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONEmmy Taylor
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
Supreme Court
ORGANIZATION
Bloomberg L.P.
ORGANIZATION
Michael Jackson
PERSONThe New York Post
ORGANIZATION
Michigan
LOCATION