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y reference in the substantive charge (Count 2, ¶ 23). Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Eps
to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three
y reference in the substantive charge (Count 2, ¶ 23). Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Eps
to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three
y reference in the substantive charge (Count 2, ¶ 23). Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Eps
to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three
y reference in the substantive charge (Count 2, ¶ 23). Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Eps
to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted). 3 Mr. Epstein has only one active passport permitting current travel — not three
t 1: Notes from the U.S. Attorney's Office for the Southern District of New York Exhibit 2: June 14, 2007 Email Exhibit 3: November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Exhibit 4: Notes from February 11, 2021 Call Exhibit 5: Notes from February 29, 2016 Meeting Exhibit 6:
ited States v. Page, 657 F.3d 126 (2d Cir. 2011) 205, 209, 210, 220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.
t 1: Notes from the U.S. Attorney's Office for the Southern District of New York Exhibit 2: June 14, 2007 Email Exhibit 3: November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Exhibit 4: Notes from February 11, 2021 Call Exhibit 5: Notes from February 29, 2016 Meeting Exhibit 6:
ited States v. Page, 657 F.3d 126 (2d Cir. 2011) 205, 209, 210, 220 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 252 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 253 United States v. Payner, 447 U.S. 727 (1980) 115, 161, 162 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.
DFL has explained, the NPA did not bind other districts, and could not. That is because the USAO-SDFL lacked the authority to do so under applicable Department of Justice guidelines: Significantly, under the governing provision of the United States Attorney's Manual, the USAO-SDFL did not have the authority to unila
United States v. Page, 657 F.3d 126 (2d Cir. 2011) 138, 140, 147 United States v. Pascarella, 84 F.3d 61 (2d Cir. 1996) 165 United States v. Paulin, 445 F.3d 211 (2d Cir. 2006) 165 United States v. Payner, 447 U.S. 727 (1980) 82, 110 United States v. Pena, 932 F. Supp. 2d 464 (S.D.N.Y. 201
1790 IN THE NEWS Justice Dept. Investigating Former New York Gov. Cuomo Over Pandemic Testimony The New York Times (05/20, Barrett) reported that the U.S. Justice Department has opened a criminal investigation into Andrew Cuomo, a leading candidate in the New York City mayoral race, over allegations that he lied to Cong
gnated meeting location, he was met by members of the FBI's Child Exploitation and Human Trafficking Task Force and was arrested. Starting in April, Paulin used an undisclosed app and "was communicating with someone who was believed to be the father of the 7- and 9-year-old boys," a police booking affi
Entities connected to both Department of Justice and Paulin

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
George W. Bush
PERSON
Virginia Giuffre
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
New York
LOCATION
Julie K. Brown
PERSONJane Doe
PERSON
Geoffrey S. Berman
PERSON
Scarlett Johansson
PERSON
Stephen Hawking
PERSON
Southern District of New York
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON