Epstein Secrets

hn Gurganus of the Middle District of Pennsylvania. This is the latest in a series of civil rights complaints and habeas corpus petitions filed by Reynolds which challenge the legality of his ongoing federal criaiinal prosecution in this district. See United States I Reynolds, Case No. 3:05-CR-493.

d in the Lackawanna County Prison, Scranton, Pennsylvania initiated this pro se petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241. Reynolds' petition is accompanied by an in forma pauperis application. For the reasons set forth below, Reynolds' petition will be dismissed as meritless.

ers, Inc., Petitioners-Ap- pellees, v. UNITED STATES of America, Respondent-Appellant. No. 474, Docket 95-6119. United States Court of Appeals, Second Circuit. Argued Aug. 81, 1996. Decided Oct. 17, 1996. Government appealed from order en- tered in the United States District Court for the Eastern Distri

d Relief. 16 CONCLUSION 17 i EFTA00104412 TABLE OF AUTHORITIES Page(s) Cases Ex parte Lange, 85 U.S. (18 Wall.) 163 (1873) 11 Morris v. Reynolds, 264 F.3d 38 (2d Cir. 2001) 12 North Carolina v. Pearce, 395 U.S. 711 (1969) II, 12, 13 United States v. Annabi, 771 F.2d 670 (2d Cir. 1985)

e's the only one who takes the blame for what happened").3 The government further asserts that Ms. Maxwell's position is not supported by subsequent Second Circuit cases that apply Annabi. (Opp. 5-6). But this argument simply begs the question. Although courts in this Circuit have applied Annabi to evaluate whe

ed its legislative authorization by imposing multiple punishments for the same offense." Brown v. Ohio, 432 U.S. 161, 165 (1977); see also Morris v. Reynolds, 264 F.3d 38, 48 (2d Cir. 2001). An indictment is multiplicitous, and therefore implicates double jeopardy, "when it charges a single offense as an

assessed on its own terms . . . based on the entire record." United States v. Maslin, 356 F.3d 191, 196 (2d Cir. 2004). In assessing the evidence, the Second Circuit applies a burden-shifting framework. The defendant carries the initial burden of making a non-frivolous showing that the two counts in fact charge

at *2 (2d Cir. Apr. 26, 2002); United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Rivera, 844 F.2d 916, 923 (2d Cir. 1988). The Second Circuit has held that language nearly identical to that in Epstein's NPA is not enough to overcome the presumption in favor of sin

ites change the Court's conclusion that the NPA does not bar the charges against her. As the Court explained in its April 16, 2021 Opinion & Order, the Second Circuit held in United States v. Annabi that "[a] plea agreement binds only the office of the United States Attorney for the district in which the plea is

jeopardy when the jury in their case is empaneled or upon the defendant's entry of a guilty plea. Crist v. Bretz, 437 U.S. 28, 35 (1978); Morris v. Reynolds, 264 F.3d 38, 49 (2d Cir. 2001). Until then, a defendant has not been put in jeopardy and the Government is free to commence a prosecution. Maxwel