This document is a court transcript from August 10, 2022, detailing a discussion about jury instructions. An attorney, Mr. Everdell, proposes an instruction regarding the credibility of a witness with a prior felony conviction, citing the case 'United States v. Berry' as a model. The opposing counsel, Mr. Rohrbach, requests time to review this new proposal, which the Court grants, suggesting the instruction be added as a standalone item.
This legal document is a filing that argues against a defendant's motion claiming prejudice. The defendant alleges that the unavailability of 'critical documentary records'—such as flight, financial, and property records related to Epstein—prevented her from challenging government assertions and testimony from a witness named Jane. The filing contends that the defendant's claims are speculative and fail to demonstrate what the missing records would have shown or that they would have been favorable to her defense.
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