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States v. Stringer, 730 E 3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00103021 United States v. Sweig, 441 F.2d 114 (2d Cir. 1971) 207, 211, 217 United States v. Tanu, 589
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
s protections, while The New York Times <https://www.nytimes.com/2020/08/24/technology/tiktok-sues-us-government-over-trump-ban.html> (8/24, Isaac, Swanson, 18.61M) calls the lawsuit "TikTok's most direct challenge to the White House." Reuters <https://www.reuters.corn/article/us-usa-china-tiktok-lawsui
regards safety." The Washington Post <https://www.washingtonpost.corn/education/2020/08/24/florida-judge-blocks-state-order- schools-reopen/> (8/24, Strauss, 14.2M) reports that an "appeal by the state means that school districts cannot immediately move to change their reopening plans for starting the 20
ms In China, Cuba Draw Scrutiny. The New York Times <https://vvww.nytimes.com/2020/10/19/us/politics/diplomat-attacks-havana- syndrome.html> (10/19, Swanson, Wong, Barnes, 18.6IM) reports, "What began as strange sounds and symptoms among more than a dozen American officials and their family members in Ch
shingtonpost.com/education/school-districts-reopening- coronavirus/2020/10/19/3791c952-0ffb-11eb-8074-0e943a9lbfO8_story.html> (10/19, A 1 , Meckler, Strauss, 14.2M) reports, "Large school districts across the country are reopening campuses to students, a slow-moving reversal driven by fear that students
ave been largely the exception." Differing Administration Response To Diplomats' Symptoms In China, Cuba Draw Scrutiny. The New York Times (10/19, Swanson, Wong, Barnes, 18.61M) reports, "What began as strange sounds and symptoms among more than a dozen American officials and their family members in C
ing and other critical care services during the pandemic." Large School Districts Are Reopening Campuses. The Washington Post (10/19, Al, Meckler, Strauss, 14.2M) reports, "Large school districts across the country are reopening campuses to students, a slow-moving reversal driven by fear that students
.57M) reports the lawsuit argues the executive order violates the Fifth Amendment's due process protections, while The New York Times (8/24, Isaac, Swanson, 18.61M) calls the lawsuit "TikTok's most direct challenge to the White House." Reuters (8/24, Wang, Stempel) reports TikTok rejected what they "ca
protection equipment. The state order to open is unconstitutional to the extent that it arbitrarily disregards safety." The Washington Post (8/24, Strauss, 14.2M) reports that an "appeal by the state means that school districts cannot immediately move to change their reopening plans for starting the 2
.57M) reports the lawsuit argues the executive order violates the Fifth Amendment's due process protections, while The New York Times (8/24, Isaac, Swanson, 18.61M) calls the lawsuit "TikTok's most direct challenge to the White House." Reuters (8/24, Wang, Stempel) reports TikTok rejected what they "ca
ipment. The state order to open is unconstitutional to the extent that it arbitrarily disregards safety." EFTA01658448 The Washington Post (8/24, Strauss, 14.2M) reports that an "appeal by the state means that school districts cannot immediately move to change their reopening plans for starting the 2
States v. Stringer, 730 F.3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00099963 United States v. Sweig, 441 F.2d 114 (2d Cir. 1971) 207,211,217 United States v. Tanu, 589 F.
ICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
States v. Stringer, 730 E 3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00077628 United States v. Sweig, 441 F.2d 114 (2d Cir. 1971) 207, 211, 217 United States v. Tanu, 589
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
States v. Stringer, 730 E 3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00039443 United States v. Sweig, 441 F.2d 114 (2d Cir. 1971) 207, 211, 217 United States v. Tanu, 589
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
States v. Stringer, 730 F.3d 120 (2d Cir. 2013) 151, 152, 153 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 120, 127 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 115 United States v. Sweig, 441 F.2d 114 (2d Cir. 1971) 139, 141, 145 United States v. Tanu, 589 F.2d 82 (2d Cir
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
Entities connected to both Swanson and Audrey Strauss

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Michael Cohen
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Donald Trump
PERSONthe Southern District
LOCATIONSouthern District
LOCATION
Denver
LOCATIONLeon Black
PERSON
United States
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Colorado
LOCATION
Alison J. Nathan
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William Barr
PERSONMartin Weinberg
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Jared Kushner
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George W. Bush
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Steven Mnuchin
PERSONDermot Shea
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