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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 →the Constitution, but a law that extends an un-expired statute of limitations does not. Stogner v. California, 539 U.S. 607, 632-33 (2003). Senator Leahy, who co- sponsored the PROTECT Act, expressed concerns in a committee report that the proposed retroactivity provision was "of doubtful constitution
Page: EFTA00020275 →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 →the Constitution, but a law that extends an un-expired statute of limitations does not. Stogner v. California, 539 U.S. 607, 632-33 (2003). Senator Leahy, who co- sponsored the PROTECT Act, expressed concerns in a committee report that the proposed retroactivity provision was "of doubtful constitution
Page: EFTA00022105 →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 →the Constitution, but a law that extends an un-expired statute of limitations does not. Stogner v. California, 539 U.S. 607, 632-33 (2003). Senator Leahy, who co- sponsored the PROTECT Act, expressed concerns in a committee report that the proposed retroactivity provision was "of doubtful constitution
Page: EFTA00029554 →assim 18 U.S.C. § 3509(aX8) 14 18 U.S.C. § 3509(k) (1990) 8 8 U.S.C. § 1101(a)(43)(M)(i) 12 Pub. L. No. 101-647 8 Other Authorities Senator Leahy, Amber Legislation, Cong. Rec. 149:50, 55147 (2003) 3 iv EFTA00028907 --- PAGE BREAK --- Ghislaine Maxwell respectfully submits this Reply Memo
pursuant Rule 2(B) of the Court's individual practices in criminal cases, the within memorandum and any accompanying exhibits upon the following: U.S. Attorney's Office, SDNY Is/ Christian Everdell EFTA00028924
Page: EFTA00028924 →Entities connected to both Leahy and U.S. Attorney's Office

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
United States
LOCATIONDistrict Court for the Southern District of New York
ORGANIZATION
Department of Justice
ORGANIZATIONJane Doe
PERSONFBI
ORGANIZATION
Alexander Acosta
PERSON
Bradley Edwards
PERSON
Donald Trump
PERSONSouthern District of Florida
LOCATIONSecond Circuit
ORGANIZATION
Reid Weingarten
PERSON
Supreme Court
ORGANIZATIONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Michael Cohen
PERSONEmmy Taylor
PERSON
Paul Cassell
PERSON