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ell with sex trafficking offenses under 18 U.S.C. § 1591 (Counts Five and Six) and has dramatically expanded the timeframe of the Mann Act 2 Ex. A (Dep't of Justice, Office of Professional Responsibility, Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of its 2006-
bandoned pursuant to the NPA, the government cannot now charge Ms. Maxwell with these offenses. Further, the NPA binds the United States Attorney's Office for the Southern District of New York ("USAO-SDNY") as to the newly-indicted counts. We understand that the Court previously ruled that under United States v. Annabi, 771 F.
V-MARRAMOHNSON EFTA00208059 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04107/2011 Page 24 of 54 In Sieverding v. United States Dep't of Justice, 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to
F.3d at 1081 (quoting Chaney, 470 U.S. at 831). That type of inquiry is exactly the one requested by Jane Does #1 and #2 — did the U.S. Attorney's Office for the Southern District of Florida violate the CVRA. Here, Petitioners' request should be examined with even greater caution than the average agency decision because it in
s been filed." 23 EFTA00078857 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 24 of 54 In Sieverding v. United States Dep't of Justice, 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to
F.3d at 1081 (quoting Chaney, 470 U.S. at 831). That type of inquiry is exactly the one requested by Jane Does #1 and #2 — did the U.S. Attorney's Office for the Southern District of Florida violate the CVRA. Here, Petitioners' request should be examined with even greater caution than the average agency decision because it in
Entities connected to both Dep't of Justice and Southern District of New York

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Ghislaine Maxwell
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONJane Doe
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSONLeon Black
PERSON
New York
LOCATION
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Michael Jackson
PERSON
Geoffrey S. Berman
PERSON