Epstein Secrets

or transaction" as the Mann Act Counts and cannot be joined. Fed. R. Crim. P. 8(a); see Halper, 590 F.2d at 430 (temporally and factually distinct Medicaid fraud and tax evasion offenses were not based on same transaction, nor were they "of the same or similar character" simply because both involved att

13 Certificate of Service 15 EFTA00091876 TABLE OF AUTHORITIES Cases Drew v. United States, 331 F.2d 85 (D.C. Cir. 1964) 6 United States v. Blakney, 941 F.2d 114 (2d Cir. 1991) 4 United States v. Botti, No. 3:08-cr-00230 (CSH), 2009 WL 3157582 (S.D.N.Y. Sept. 25, 2009) 4, 9 United States v.

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different 53 Whi

"no one characteristic is always sufficient to establish 'similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different 53 Whi

"no one characteristic is always sufficient to establish `similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different 53 Whi

"no one characteristic is always sufficient to establish `similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different in eac

"no one characteristic is always sufficient to establish `similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different While

"no one characteristic is always sufficient to establish `similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980