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prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with a
Page: EFTA00020265 →five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00020266 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen
Page: EFTA00020266 →of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged
Page: EFTA00020281 →prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with a
Page: EFTA00022095 →five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00022096 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen
Page: EFTA00022096 →of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged
Page: EFTA00022111 →he NPA to plead guilty in Florida state court to soliciting minors for prostitution and to serve eighteen months in a county jail. Id. In exchange, the U.S. Attorney's Office agreed not to charge him with federal crimes in the Southern District of Florida stemming from its investigation of his conduct between 2001 and 20
Page: EFTA00029542 →five enumerated offenses; (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and (3) "any offenses that arose from the Federal Grand Jury investigation." 6 EFTA00029545 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Documen
Page: EFTA00029545 →Filed 04/16/21 Page 21 of 34 Moreover, the Government has agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties to negotiate and propose a full schedule for all remaining pretrial disclos
Page: EFTA00029560 →Entities connected to both Stringer and U.S. Attorney's Office

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONJane Doe
PERSON
United States
LOCATION
Bradley Edwards
PERSONSouthern District of Florida
LOCATIONFBI
ORGANIZATIONSecond Circuit
ORGANIZATIONMartin Weinberg
PERSON
Julie K. Brown
PERSONJeffrey Pagliuca
PERSON
David Boies
PERSON
Supreme Court
ORGANIZATION
Virginia Giuffre
PERSON
Reid Weingarten
PERSON
Office of Professional Responsibility
ORGANIZATION
Alison J. Nathan
PERSON
Palm Beach
LOCATION
Giglio
PERSON