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United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 156,157,158 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 66 United States v. Vickers, 708 F. App'x 732 (2d Cir. 2017) 256 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8,2014) passim United
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
used to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00100121 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
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,
nited States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 156, 157, 158 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 66 United States v. Vickers, 708 F. App'x 732 (2d Cir. 2017) 256 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014) passim United
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
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00077786 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
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,
nited States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 156, 157, 158 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 66 United States v. Vickers, 708 F. App'x 732 (2d Cir. 2017) 256 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014) passim United
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
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00039601 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
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,
23 United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 107, 108 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 45 United States v. Vickers, 708 F. App'x 732 (2d Cir. 2017) 168 United States v. Vickers, No. 13-CR-I28-A, 2014 WL 1838255 (W.D.N.Y. May 8, 2014) 37, 38, 39, 154 United S
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
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, 13 Cr. 128 (MA) (HKS), 2014 WL 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging enticement of a minor, in
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,
. Several victims told police that she was involved in orgies with Epstein and underage girls. Ross, Groff and Kellen, now known by her married name, Vickers, were schedulers who arranged his underage sex sessions, according to the FBI and police. Marcinkova and Kellen, through their attorneys, declined t
inal charges were resolved by a guilty plea to a single Florida state law charge and a non-prosecution agreement (a “NPA”) with the U.S. Attorney for the Southern District of Florida. Unknown to the public and the victims at the time, Epstein’s lawyers, including Dershowitz, were pressuring the Government to commit to t
nited States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 156, 157, 158 United States v. Valona, 834 F.2d 1334 (7th Cir. 1987) 66 United States v. Vickers, 708 F. App'x 732 (2d Cir. 2017) 256 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014) passim United
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
Entities connected to both Vickers 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
New York
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
Donald Trump
PERSON
Jay Lefkowitz
PERSON