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Mentions
43 United States v. Al Kassar, 660 F.3d 108 (2d Cir. 2011) 154 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 77,78,81 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
knowledge of the scheme's existence. A defendant may commit perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the qu
cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), lijt has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,
3 United States v. Al Kassar, 660 F.3d 108 (2d Cir. 2011) 154 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 77, 78, 81 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998)
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
knowledge of the scheme's existence. A defendant may commit perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the qu
cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,
3 United States v. Al Kassar, 660 F.3d 108 (2d Cir. 2011) 154 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 77, 78, 81 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998)
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
knowledge of the scheme's existence. A defendant may commit perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the qu
cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,
v. Al Kassar, 660 F.3d 108 (2d Cir. 2011) 105 viii EFTA00095075 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 53, 55 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 125 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998) 150 United States v. Amato, 15 F.3d 230 (2d Cir. 1994)
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
knowledge of the scheme's existence. A defendant may commit perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the qu
edure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), '[i]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,
United States v. Al Kassar, 660 F.3d 108 (2d Cir. 2011) 154 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 77, 78, 81 United States v. Alberti, 568 F.2d 617 (2d Cir. 1977) 187 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 27 United States v. Alfonso, 143 F.3d 772 (2d. Cir. 1998
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
knowledge of the scheme's existence. A defendant may commit perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the qu
cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,
Entities connected to both Alberti and the Southern District

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Prince Andrew
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
A. Marie Villafana
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Ken Starr
PERSON
Palm Beach
LOCATION
Stephen Hawking
PERSON