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294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Joseph berg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S
152 VIII. There Is No Basis to Strike Any Portion of the Indictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as '\lultiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. Th
is fundamentally ambiguous or imprecise, the truthfulness of [the defendant's] answers is an issue for the jury." Id. at 304; see United States v. Kaplan, 758 F. App'x 34, 39 (2d Cir. 2018) (same); cf. Lighte, 782 F.2d at 374 (finding the evidence insufficient where some answers "were literally true
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they am m
) 294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S.
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
is fundamentally ambiguous or imprecise, the truthfulness of [the defendant's] answers is an issue for the jury." Id. at 304; see United States v. Kaplan, 758 F. App'x 34, 39 (2d Cir. 2018) (same); cf. Lighte, 782 F.2d at 374 (finding the evidence insufficient where some answers "were literally true
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
) 294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S.
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
is fundamentally ambiguous or imprecise, the truthfulness of [the defendant's] answers is an issue for the jury." Id. at 304; see United States v. Kaplan, 758 F. App'x 34, 39 (2d Cir. 2018) (same); cf. Lighte, 782 F.2d at 374 (finding the evidence insufficient where some answers "were literally true
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
ed States v. Jones, 482 F.3d 60 (2d Cir. 2006) 169 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) 169, 170, 172, 173 United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 121 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 202 United States v. Kidd, 386 F. Supp.3d 364 (S.
limitations set forth in § 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
is fundamentally ambiguous or imprecise, the truthfulness of [the defendant's] answers is an issue for the jury." Id. at 304; see United States v. Kaplan, 758 F. App'x 34, 39 (2d Cir. 2018) (same); cf. Lighte, 782 F.2d at 374 (finding the evidence insufficient where some answers "were literally true
ree and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. 168 EFTA00095260 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
) 294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
is fundamentally ambiguous or imprecise, the truthfulness of [the defendant's] answers is an issue for the jury." Id. at 304; see United States v. Kaplan, 758 F. App'x 34, 39 (2d Cir. 2018) (same); cf. Lighte, 782 F.2d at 374 (finding the evidence insufficient where some answers "were literally true
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
Entities connected to both Kaplan and The Defendant's Motion

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
George Mitchell
PERSON
Prince Andrew
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Scarlett Johansson
PERSON
Julie K. Brown
PERSON
Ghislaine Maxwell
PERSON
Michael Jackson
PERSON
United States
LOCATION
Colorado
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Chris Tucker
PERSON
Virginia Giuffre
PERSON
Michigan
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Minnesota
LOCATIONFBI
ORGANIZATION
Supreme Court
ORGANIZATIONDarren Indyke
PERSON
Stephen Hawking
PERSON