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ence methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3466370, at *13-14 (S.D.N.Y. Aug. 31, 2010) (quoting United States v. Simmons, 470 F.3d 1115, 1123 (5th Cir. 2006)). IL Discussion As a preliminary matter, the Defense argues that the additional materials filed by the Gove
bout delayed disclosure are "are outside the ken of the 8 EFTA00040114 average person," and so appropriate for expert testimony. United States v. Felder, 993 F.3d 57, 72 (2d Cir. 2021). Nor would admission of these opinions cause unfair Rule 403 prejudice since they are relevant rebuttal to impeachm
ence methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3466370, at *13-14 (S.D.N.Y. Aug. 31, 2010) (quoting United States v. Simmons, 470 F.3d 1115, 1123 (5th Cir. 2006)). IL Discussion As a preliminary matter, the Defense argues that the additional materials filed by the Gove
bout delayed disclosure are "are outside the ken of the 8 EFTA00094660 average person," and so appropriate for expert testimony. United States v. Felder, 993 F.3d 57, 72 (2d Cir. 2021). Nor would admission of these opinions cause unfair Rule 403 prejudice since they are relevant rebuttal to impeachm
ence methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3466370, at *13-14 (S.D.N.Y. Aug. 31, 2010) (quoting United States v. Simmons, 470 F.3d 1115, 1123 (5th Cir. 2006)). IL Discussion As a preliminary matter, the Defense argues that the additional materials filed by the Gove
bout delayed disclosure are "are outside the ken of the 8 EFTA00094649 average person," and so appropriate for expert testimony. United States v. Felder, 993 F.3d 57, 72 (2d Cir. 2021). Nor would admission of these opinions cause unfair Rule 403 prejudice since they are relevant rebuttal to impeachm
ence methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3466370, at *13-14 (S.D.N.Y. Aug. 31, 2010) (quoting United States v. Simmons, 470 F.3d 1115, 1123 (5th Cir. 2006)). IL Discussion As a preliminary matter, the Defense argues that the additional materials filed by the Gove
Page: EFTA00016472 →ure are "are outside the ken of the 8 EFTA00016478 --- PAGE BREAK --- average person," and so appropriate for expert testimony. United States v. Felder, 993 F.3d 57, 72 (2d Cir. 2021). Nor would admission of these opinions cause unfair Rule 403 prejudice since they are relevant rebuttal to impeachm
Page: EFTA00016479 →Entities connected to both Russell Simmons and Felder

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Prince Andrew
PERSON
United States
LOCATIONLeon Black
PERSON
Bloomberg L.P.
ORGANIZATION
Scarlett Johansson
PERSON
Colorado
LOCATION
Bill Clinton
PERSON
New York
LOCATIONMaria Farmer
PERSON
Bradley Edwards
PERSON
Department of Justice
ORGANIZATION
Harvey Weinstein
PERSON
George Mitchell
PERSON
Supreme Court
ORGANIZATION
Michigan
LOCATIONPeggy Siegal
PERSON
Paul Cassell
PERSON