Epstein Secrets

exists to justify nondisclosure of witnesses to opposing counsel and thus noncompliance with Rule 12.1." 198 Similarly, in United States v. Elizondo, the Seventh Circuit cited Causey for the proposition that the protection of potential witnesses could justify postponing disclosure. '°? Following the reasoning of the S

e subpoena ex parte. 239 Fed. R. Crim. P. 17(c). 240 See E-mail from Rod Rosenstein, U.S. Attorney for the District of Maryland, to Russell Butler, Maryland Crime Victims’ Resource Center, Inc. (Jan. 3, 2007), reprinted in Testimony of Russell Butler to the Federal Criminal Rules Advisory Comm. App. A (Ja

ve aided and abetted interna- tional terrorism. Bowm v. Quranic Litera- cy Inst. & Holy Land Found. 127 F.Supp.2d 1002, 1018 (N.D.IIL2001) (“Bom I”). The Seventh Circuit affirmed the decision and held that the parents of a yeshiva student killed in 1996 in Israel by members of the military wing of Hamas could prove th

d Resource’s Chairman by an executive of SBG. Ashton Complaint 1459; Burnett Complaint { 328. Plaintiffs claim that SBG had an address in Rockville, Maryland until very recently. Ashton Complaint 1545; Burnett Com- plaint 1318. SBG claims the Rockville address was the headquarters of a sepa- rately incorpo

nited States corporations based in Texas, and, during a trip to the United States in 1989, he met with President George H.W. Bush and the governor of Maryland. (Plaintiffs’ Opp’n to Prince Salman Mot. to Dismiss at 21-22; see generally Parrett Aff.) Additionally, Plaintiffs claim that Prince Salman’s son at

at 1015 (finding conduct that violates § 2339A would be sufficient to meet the definition of “international terrorism” in § 2333). This Court adopts the Seventh Circuit’s requirement that Plaintiffs plead that Defendants knew of al Qaeda’s illegal activities, “that they desired to help those activities succeed, and the