Epstein Secrets

age and drafting history of the NPA does not "affirmatively appear" to bind this District 3 EFTA00103764 as to the SI Indictment counts. However, Annabi, by its own terms, is inapposite to the circumstances of this case, where one federal district has agreed that "the United States" will abandon cer

he Double Jeopardy Clause, and (3) grant her other requested relief. Dated: May 7, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

-SDNY") because it does not "affirmatively appear" to apply to this District. (Opp. at 2-7). But as we explained in our opening memorandum ("Mem."), Annabi is inapposite to the circumstances of this case. Annabi expressly stated that it was not addressing a situation, like the one here, where one feder

ements as Brady material, and (4) grant her other requested relief. Dated: May 28, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue ISO Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East

ecution of Potential Co-Conspirators Is Not Limited to the SDFL. 18 1. The NPA is binding on the USAO in this District 18 2. United States v. Annabi does not alter the analysis. 19 a. There is an "affirmative appearance" that the co-conspirator immunity provision was intended to apply outsid

ANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim At

bail proceeding, that are not even foreclosed by the cases the government does cite to you. They cite to you the -- I'm going to skip this one, the Annabi case, A-N-N-A-B-I case, which says, "The plea the office of the U.S. Attorney for the plea is entered unless it affirmatively agreement binds onl

AINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East