Epstein Secrets

do not qualify as offenses involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each statutory offense. See Bridges v. United States, 346 U.S. 209, 221 (1953). In Maxwell's view, 9 EFTA00020269 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 207 Filed 04/16

ury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so. See United States v. Halper, 590 F.2d 422, 430 (2d Cir. 1978). Second, the evidence presented on the Mann Act counts may prejudice the jury's ability to fairly evaluate Maxwel

do not qualify as offenses involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each statutory offense. See Bridges v. United States, 346 U.S. 209, 221 (1953). In Maxwell's view, 9 EFTA00022099 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 207 Filed 04/16

ury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so. See United States v. Halper, 590 F.2d 422, 430 (2d Cir. 1978). Second, the evidence presented on the Mann Act counts may prejudice the jury's ability to fairly evaluate Maxwel

do not qualify as offenses involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each statutory offense. See Bridges v. United States, 346 U.S. 209, 221 (1953). In Maxwell's view, 9 EFTA00029548 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 208 Filed 04/16

ury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so. See United States v. Halper, 590 F.2d 422, 430 (2d Cir. 1978). Second, the evidence presented on the Mann Act counts may prejudice the jury's ability to fairly evaluate Maxwel