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LEASE TAKE NOTICE that upon the annexed Affirmation of Robert Lewis, made on the 13th day of September, 2010 and exhibit annexed thereto, Petitioner Freeman Lewis LLP will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 a.m. on October II, 2010, or as soon thereafter as
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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 id.), but omits the portion of that letter in which the Government explained that, as
Thus, the defendant's claim that she no longer has access to certain evidence is not a proper basis to dismiss the Indictment. See United States v. Donau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973) ("A bare allegation that records have been lost or destroyed, which might relate Ig The Government notes t
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
Thus, the defendant's claim that she no longer has access to certain evidence is not a proper basis to dismiss the Indictment. See United States v. Donau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973) ("A bare allegation that records have been lost or destroyed, which might relate Ig The Government notes t
Entities connected to both Freeman and Donau

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