Epstein Secrets

-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

ernment offers only one argument for why it should be permitted to prosecute Ms. Maxwell for these offenses. Relying on the Court's prior ruling and the Second Circuit's decision in United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) (per curiam), the government asserts that the NPA does not bind the U.S. Attorney'

irmatively establish that a more expansive interpretation was contemplated." United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), aff'd, 867 F.2d 1425 (2d Cir. 1988)(tbl.). To meet this burden, a defendant must establish that either the text of the agreement

ircuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactively extend the limitations period for still-viable pr

e.g., United States v. Israel, 05 Cr. 1039 (CM), Dkt. No. 25; United States v. &ornate, et aL, 09 Cr. 558 (CM), Dkt. No. 183, 200; United States v. Annabi, 10 Cr. 07 (CM), Dkt. No. 45; United States v. Arid, 12 Cr. 24 (LAP), Dkt. No. 115, 117; United States v. Reeves, et aL, 16 Cr. 372 (VEC), Dkt. No.

und the time of the defendant's trial, or some combination thereof. Id. Ultimately, the district court in Rioux found that the teaching of Duren and the Second Circuit's subsequent cases is that "the court must assess representativeness in the context of the systematic defect identified by the defendant." Id. at 156

irmatively establish that a more expansive interpretation was contemplated." United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), aff'd, 867 F.2d 1425 (2d Cir. 1988)(tbl.). To meet this burden, a defendant must establish that either the text of the agreement

ircuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively extend the limitations period for still-viable pro

e.g., United States v. Israel, 05 Cr. 1039 (CM), Dkt. No. 25; United States v. Cromitie, et at, 09 Cr. 558 (CM), Dkt. No. 183, 200; United States v. Annabi, 10 Cr. 07 (CM), Dkt. No. 45; United States v. Arici, 12 Cr. 24 (LAP), Dkt. No. 115, 117; United States v. Reeves, et at, 16 Cr. 372 (VEC), Dkt. No

und the time of the defendant's trial, or some combination thereof. Id. Ultimately, the district court in Rioux found that the teaching of Duren and the Second Circuit's subsequent cases is that "the court must assess representativeness in the context of the systematic defect identified by the defendant." Id. at 156

irmatively establish that a more expansive interpretation was contemplated." United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), aff'd, 867 F.2d 1425 (2d Cir. 1988)(tbl.). To meet this burden, a defendant must establish that either the text of the agreement

ircuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively extend the limitations period for still-viable pro

e.g., United States v. Israel, 05 Cr. 1039 (CM), Dkt. No. 25; United States v. Cromitie, et at, 09 Cr. 558 (CM), Dkt. No. 183, 200; United States v. Annabi, 10 Cr. 07 (CM), Dkt. No. 45; United States v. Arici, 12 Cr. 24 (LAP), Dkt. No. 115, 117; United States v. Reeves, et at, 16 Cr. 372 (VEC), Dkt. No

und the time of the defendant's trial, or some combination thereof. Id. Ultimately, the district court in Rioux found that the teaching of Duren and the Second Circuit's subsequent cases is that "the court must assess representativeness in the context of the systematic defect identified by the defendant." Id. at 156

irmatively establish that a more expansive interpretation was contemplated." United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), ard, 867 F.2d 1425 (2d Cir. 1988). To meet this burden, a defendant must establish that either the text of the agreement or the "

nited States v. Leo Sure Chief, 438 F.3d 920, 922-25 (9th Cir. 2006); United States v. Jeffiies, 405 F.3d 682, 685 (8th Cir. 2005). Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactively extend the limitations period for still-viable pr

e.g., United States v. Israel, 05 Cr. 1039 (CM), Dkt. No. 25; United States v. Cromitie, et at, 09 Cr. 558 (CM), Dkt. No. 183, 200; United States v. Annabi, 10 Cr. 07 (CM), Dkt. No. 45; United States v. Arici, 12 Cr. 24 (LAP), Dkt. No. 115, 117; United States v. Reeves, et al., 16 Cr. 372 (VEC), Dkt. N

und the time of the defendant's trial, or some combination thereof. Id. Ultimately, the district court in Rioux found that the teaching of Duren and the Second Circuit's subsequent cases is that "the court must assess representativeness in the context of the systematic defect identified by the defendant." Id. at 156

irmatively establish that a more expansive interpretation was contemplated." United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), aff'd, 867 F.2d 1425 (2d Cir. 1988)(tbl.). To meet this burden, a defendant must establish that either the text of the agreement

rcuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief, 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactively extend the limitations period for still-viable pr