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nd Three. Conspiracy charges may be brought "in any district in which an overt act in furtherance of the conspiracy was committed." United States v. Lange, 834 F.3d 58, 68 (2d Cir. 2016). Here, the calls from New York to schedule appointments and the packages 2021.01.26 EFTA_00023140 EFTA02731246
lly relevant to our case. We are in the process of reviewing that subset of emails. Third, we are still in the process of loading scans of the full USAO-SDFL file into Relativity so that our team can conduct a full review of that file. Due to technical issues with the vendor who scanned the files in Flori
much to prevent the criminal from being twice punished for the same offense as from being twice tried for it. Pearce, 395 U.S. at 717-18 (quoting Lange, 85 U.S. (18 Wall.) at 168) (emphasis added). Here, it is beyond dispute that Epstein was already punished for the offenses covered by the NPA. The
st levied her accusations more than a decade ago. The Palm Beach FBI and the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And
The Court Should Grant Ms. Maxwell's Other Requested Relief. 16 CONCLUSION 17 i EFTA00104412 TABLE OF AUTHORITIES Page(s) Cases Ex parte Lange, 85 U.S. (18 Wall.) 163 (1873) 11 Morris v. Reynolds, 264 F.3d 38 (2d Cir. 2001) 12 North Carolina v. Pearce, 395 U.S. 711 (1969) II, 12, 13
secutorial overreach. It is no mystery what happened here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "pote
Entities connected to both Lange and USAO-SDFL

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Southern District of New York
ORGANIZATIONEmmy Taylor
PERSON
Alexander Acosta
PERSON
Harvey Weinstein
PERSON
Brady
PERSONThompson
PERSONSecond Circuit
ORGANIZATION
New York
LOCATIONMaria Farmer
PERSON
Joe Biden
PERSON
George W. Bush
PERSON
Michael Cohen
PERSON
Colorado
LOCATION