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ng a bank in Manhattan on April 22 cannot offer as evidence to disprove the charged crime that he did not rob the bank's branches in Brooklyn or the Bronx on April 22 or that he did not rob the Manhattan branch on April 20, 21, 23, and 24, because this evidence is irrelevant to the charge that he robb
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
ne for the White Plains courthouse. Id. at Art. III.B. The Manhattan Master Jury Wheel draws from voter lists from the following counties: New York, Bronx, Westchester, Putnam, and Rockland. See id. at Art. III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: W
sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys 212 EFTA00103237
ng a bank in Manhattan on April 22 cannot offer as evidence to disprove the charged crime that he did not rob the bank's branches in Brooklyn or the Bronx on April 22 or that he did not rob the Manhattan branch on April 20, 21, 23, and 24, because this evidence is irrelevant to the champ that he robbe
ICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
ne for the White Plains courthouse. Id. at Art. III.B. The Manhattan Master Jury Wheel draws from voter lists from the following counties: New York, Bronx, Westchester, Putnam, and Rockland. See id. at Art. III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: W
sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: /s Assistant United States Attorneys (212) 637-2225 212 EFTA00100179
ng a bank in Manhattan on April 22 cannot offer as evidence to disprove the charged crime that he did not rob the bank's branches in Brooklyn or the Bronx on April 22 or that he did not rob the Manhattan branch on April 20, 21, 23, and 24, because this evidence is irrelevant to the charge that he robb
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
ne for the White Plains courthouse. Id. at Art. III.B. The Manhattan Master Jury Wheel draws from voter lists from the following counties: New York, Bronx, Westchester, Putnam, and Rockland. See id. at Art. III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: W
sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00077844
ng a bank in Manhattan on April 22 cannot offer as evidence to disprove the charged crime that he did not rob the bank's branches in Brooklyn or the Bronx on April 22 or that he did not rob the Manhattan branch on April 20, 21, 23, and 24, because this evidence is irrelevant to the charge that he robb
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
ne for the White Plains courthouse. Id. at Art. III.B. The Manhattan Master Jury Wheel draws from voter lists from the following counties: New York, Bronx, Westchester, Putnam, and Rockland. See id. at Art. III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: W
sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 212 EFTA00039659
ng a bank in Manhattan on April 22 cannot offer as evidence to disprove the charged crime that he did not rob the bank's branches in Brooklyn or the Bronx on April 22 or that he did not rob the Manhattan branch on April 20, 21, 23, and 24, because this evidence is irrelevant to the charge that he robb
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
ne for the White Plains courthouse. Id. at Art. III.B. The Manhattan Master Jury Wheel draws from voter lists from the following counties: New York, Bronx, Westchester, Putnam, and Rockland. See id. at Art. III.C. The White Plains Master Jury Wheel draws from voter lists from the following counties: W
sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 211 EFTA00095303
Entities connected to both Bronx and Audrey Strauss

Jeffrey Epstein
PERSON
Ghislaine Maxwell
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Prince Andrew
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Department of Justice
ORGANIZATION
Michael Cohen
PERSON
Marc Rich
PERSONSouthern District
LOCATION
Denver
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Donald Trump
PERSONthe Southern District
LOCATIONLeon Black
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United States
LOCATIONJeffrey Pagliuca
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George W. Bush
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Colorado
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William Barr
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New Hampshire
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Alison J. Nathan
PERSONFBI
ORGANIZATIONMartin Weinberg
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