5
Shared Docs
5
Same-Page
10 / 5
Mentions
nited States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207,213,214,217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 1 I United States v. Rutkoske, 506 F.3d 1
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusoiy allegations, but it
er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified pos &WadiDef. Mem. 3, Ex. E at 2-3). The U
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 143 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 139, 142, 143, 145 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 182, 190 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 4, 9 United States v. Rutkoske, 506 F.3d 170
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
e Department reports. Although AUSA-1 does not now recall the attorneys providing her with any 65 EFTA00095157 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through
Entities connected to both Russo and Ex Pane Applications

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONEmmy Taylor
PERSON
Scarlett Johansson
PERSONCollins
PERSONThompson
PERSONAnnabi
PERSONWalker
PERSONTracy
PERSONBortnovsky
PERSONFBI
ORGANIZATION
Giglio
PERSON
Southern District of New York
ORGANIZATIONthe Southern District
LOCATION
Alberto Gonzales
PERSON
Supreme Court
ORGANIZATIONSantobello
PERSON
Eric Holder
PERSONSalameh
PERSON