Epstein Secrets

274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 248 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003

create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." Salameh, 152 F.3d at 120 (citations and internal quotation marks omitted). This rule also extends to plea agreements that use the term "United States." See

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 248 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003

create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." Salameh, 152 F.3d at 120 (citations and internal quotation marks omitted). This rule also extends to plea agreements that use the term "United States." See

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

182, 190 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 4, 9 United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 163 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 4, 5, 161 xix EFTA00095086 United States v. Salerno, 481 U.S. 739 (1987) 104 United States v. Salmonese, 352 F.

create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." Salameh, 152 F.3d at 120 (citations and internal quotation marks omitted). This rule also extends to plea agreements that use the term "United States." See

limitations set forth in § 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 248 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 200

create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." Salameh, 152 F.3d at 120 (citations and internal quotation marks omitted). This rule also extends to plea agreements that use the term "United States." See

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

74, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 1 I United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 248 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 200

152 VIII. There Is No Basis to Strike Any Portion of the Indictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as '\lultiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. Th

in the indictment was committed by one or more of the members of the conspiracy in furtherance of the objectives of the conspiracy." United Staten. Salameh, 152 F.3d 88, 14546 (2d Cir. 1998). Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor V

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they am m

the indictment was committed by one or more of the members of the conspiracy in furtherance of the objectives of the conspiracy." United States v. Salameh, 152 F.3d 88, 145-46 (2d Cir. 1998). Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor

ree and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. 168 EFTA00095260 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are