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eless, the Government will also provide a non-exhaustive list of U.S.-based issuing banks to the defendants, including Issuing Banks located within the Southern District of New York.° D. Other Evidentiary Detail Finally, Akhavan and Weigand seek an order compelling the Government to set forth a multitude of details
13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 7. 8 United States v. Mahaffy, 446 F. Supp. 2d 115 (E.D.N.Y. 2006) 10 United States v. Mandell, 710 F. Supp. 2d 368 (S.D.N.Y. 2010) 19 United States v. Marcus, 628 F.3d 36 (2d Cir. 2010) 6 United States v. Middendorf, No. 18-CR-36 (JPO), 20
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 United States v. Mandell, 710 F. Supp. 2d 368 (S.D.N.Y. 2010) 267 United States v. Marcus, 628 F.3d 36 (2d Cir. 2010) 248 United States v. Mariamma Vijua, No. 15 Cr. 2
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
83 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (AJN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 United States v. Mandell, 710 F. Supp. 2d 368 (S.D.N.Y. 2010) 267 United States v. Marcus, 628 F.3d 36 (2d Cir. 2010) 248 United States v. Marianna Vljua, No. 15 Cr. 2
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 United States v. Mandell, 710 F. Supp. 2d 368 (S.D.N.Y. 2010) 267 United States v. Marcus, 628 F.3d 36 (2d Cir. 2010) 248 United States v. Mariamma Vijua, No. 15 Cr. 2
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 United States v. Mandell, 710 F. Supp. 2d 368 (S.D.N.Y. 2010) 267 United States v. Marcus, 628 F.3d 36 (2d Cir. 2010) 248 United States v. Mariamma Vijua, No. 15 Cr. 2
w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C
S. 783 (1977) 52, 53, 54, 55 United States v. Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 174, 176, 177 United States v. Mandell, 710 F. Supp. 2d 368 (S.D.N.Y. 2010) 175 United States v. Marcus, 628 F.3d 36 (2d Cir. 2010) 163 United States v. Marion, 404 U.S. 307 (1971)
Entities connected to both the Southern District and Mandell

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Prince Andrew
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONLeon Black
PERSON
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
Donald Trump
PERSON
A. Marie Villafana
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Ken Starr
PERSON