Epstein Secrets

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

rges a single offense as an offense multiple times, in separate counts, when, in law and fact, only one crime has been committed." United States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999); see also United States v. Jones, 482 F.3d 60, 72 (2d Cir. 2006) ("A claim of multiplicity cannot succeed, however

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

rges a single offense as an offense multiple times, in separate counts, when, in law and fact, only one crime has been committed." United States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999); see also United States v. Jones, 482 F.3d 60, 72 (2d Cir. 2006) ("A claim of multiplicity cannot succeed, however

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

rges a single offense as an offense multiple times, in separate counts, when, in law and fact, only one crime has been committed." United States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999); see also United States v. Jones, 482 F.3d 60, 72 (2d Cir. 2006) ("A claim of multiplicity cannot succeed, however

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. 123 EFTA

rges a single offense as an offense multiple times, in separate counts, when, in law and fact, only one crime has been committed." United States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999); see also United States v. Jones, 482 F.3d 60, 72 (2d Cir. 2006) ("A claim of multiplicity cannot succeed, however

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

rges a single offense as an offense multiple times, in separate counts, when, in law and fact, only one crime has been committed." United States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999); see also United States v. Jones, 482 F.3d 60, 72 (2d Cir. 2006) ("A claim of multiplicity cannot succeed, however

EMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION TO DISMISS EITHER COUNT ONE OR COUNT THREE OF THE SUPERSEDING INDICTMENT AS MULTIPLICITOUS Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim

States v. Carter, 576 F.2d 1061, 1064 (3d Cir.1978); and United States v. Langford, 946 F.2d 798, 802 (11th Cir.1991). 2 See also United States v. Chacko, 169 F.3d 140, 145 (2d Cir.1999) (A multiplicitous indictment creates an exaggerated impression of a defendant's criminal activity by charging "an o