Epstein Secrets

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

99 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 234 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 45 Fisher v. United St

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (RJS), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of remembering the exact

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

99 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (RJS), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 234 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 45 Fisher v. United S

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), lijt has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of remembering the exact

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

99 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 234 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 45 Fisher v. United St

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, lbJecause minors often are not capable of remembering the exact d

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

99 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 234 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 45 Fisher v. United St

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, lbJecause minors often are not capable of remembering the exact d

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

1. v. United States, 32, 104 33 86 749 F.3d 999 (11th Cir. 2014) 117, 118, 119 Dowling v. United States, 493 U.S. 342 (1990) 52 Edwards v. Mazzuca, No 00 Civ. 2290 (RIS), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 155 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 34 Falter, 23 F.3d 3

edure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), '[i]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

Young, 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation 154 EFTA00095246 mark omitted) (quoting Edwards v. Mazzuca, No 00 Civ. 2290 (12.1S), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of remembering the exac