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opened its investigation and remained ongoing after the Indictment in this case was filed.23 The defendant quotes the Government's letter to Judge Freeman requesting permission to intervene and stay Doe v. Indyke (see hi.), but omits the portion of that letter in which the Government explained that, as
he defendant invites the Court to engage in a balancing test that weighs the prejudice to the defendant against the Government's reasons for delay. (Del Mot. 7 at 5,6 n.4). This Court should reject the defendant's invitation. The defendant cites United States v. Brand, 556 F.2d 1312, 1317 n.7 (5th Cir.
opened its investigation and remained ongoing after the Indictment in this case was filed.23 The defendant quotes the Government's letter to Judge Freeman requesting permission to intervene and stay Doe v. Indyke (see id.), but omits the portion of that letter in which the Government explained that, as
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
opened its investigation and remained ongoing after the Indictment in this case was filed.23 The defendant quotes the Government's letter to Judge Freeman requesting permission to intervene and stay Doe v. Indyke (see id.), but omits the portion of that letter in which the Government explained that, as
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
Entities connected to both Freeman and Del Mot

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSONMaria Farmer
PERSON
Michael Jackson
PERSON
United States
LOCATIONMartin Weinberg
PERSONJane Doe
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Colorado
LOCATION
Department of Justice
ORGANIZATIONEmmy Taylor
PERSON
David Boies
PERSON
George Mitchell
PERSON
Minnesota
LOCATION