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axwell is a stunning example of prosecutorial 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 pros
79) 13, 14 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 10 United States v. Dionisio, 503 F.3d 78 (2d Cir. 2007) 12 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 6, 7, 10 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 7 United States v. Korfant, 771 F.2d 660 (2d C
t because Annabi did not address the circumstances of this case; it is also consistent with fundamental fairness. As the Third Circuit cautioned in Gebbie, individual U.S. Attorney's Offices should not view themselves as "sovereigns of autonomous fiefdoms" with the ability to charge a defendant with t
ive and Six Allege the Same Offenses that Were Part of the Florida Investigation and Are Covered by the Plain Terms of the NPA 6 B. The NPA Binds the Southern District of New York as to Counts Five and Six. 11 C. Counts One and Three Must Also Be Dismissed 17 II. Prosecuting Ms. Maxwell on Counts Five and S
20 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 17 United States v. Garcia-Gonzalez, 714 F.3d 306 (5th Cir. 2013) 21 United States v. Gebbie, 294 F.3d 540 (3rd Cir. 2002) 14, 15, 16, 17 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 16 United States v. Harvey, 791 F.2
torneys representing plaintiffs in civil litigation against Ms. Maxwell met with a section chief in the United States Attorney's Office ("USAO") for the Southern District of New York ("SDNY") and pitched the idea of bringing a criminal case against Ms. Maxwell for conduct similar, if not identical, to that alleged in
82 (2d Cir. 2019) 13, 26, 29, 30 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 16, 17 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 24, 25 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d
torneys representing plaintiffs in civil litigation against Ms. Maxwell met with I section chief in the United States Attorney's Office ("USAO") for the Southern District of New York ("SDNY") and pitched the idea of bringing I criminal case against Ms. Maxwell for conduct similar, if not identical, to that alleged in
82 (2d Cir. 2019) 13, 26, 29, 30 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 16, 17 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 24, 25 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d
Entities connected to both the Southern District and Gebbie

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Alexander Acosta
PERSON
New York
LOCATION
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
Julie K. Brown
PERSON
Michael Cohen
PERSON
Harvey Weinstein
PERSONCourtney Wild
PERSON
Samantha Power
PERSON
Colorado
LOCATIONSecond Circuit
ORGANIZATIONJeffrey Pagliuca
PERSON
Brady
PERSON