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d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 11 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
rt that the defendant "had not engaged in any business activity during the preceding six years").54 Accordingly, and consistent with the holding in Ruiz and Broccolo, this Court should deny the severance motion. 54 While the defendant may argue that the fact that her deposition, unlike Ruiz, did not involve crim
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
Entities connected to both New Mexico and Ruiz and Broccolo

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Palm Beach
LOCATION
Bradley Edwards
PERSONJane Doe
PERSON
Virginia Giuffre
PERSON
Stephen Hawking
PERSON
Colorado
LOCATION
Scarlett Johansson
PERSONMaria Farmer
PERSON
Julie K. Brown
PERSON
George Mitchell
PERSON
Michael Jackson
PERSON
Bill Richardson
PERSON
David Boies
PERSON
United Kingdom
LOCATION
Michigan
LOCATIONDoug Band
PERSON