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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
United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. &ouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. DAtnico, 734 F. Supp. 2d 321 (S.D.N.Y. 2
v. Corr, 543 F.2d 1042 (2d Cir. 1976) 181 xii EFTA00099953 United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. &ouch, 84 F.3d 1497 (5th Cir. 1996)
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
United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y.
v. Corr, 543 F.2d 1042 (2d Cir. 1976) 181 xii EFTA00077618 United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996)
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
United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y.
v. Corr, 543 F.2d 1042 (2d Cir. 1976) 181 xii EFTA00039433 United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996)
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
v. 593 (1958) 130 Sexual Abuse Prosecutions, 77 J. Crim. L. & Criminology 1 (1986) 24 United States v. Balde, 20 Cr. 281 206 United States v. Cromitie, et aL, 09 Cr. 558 (CM) 194 United States v. Drago, No., 18 Cr. 0394 59 United States v. Guerrier, 18 Cr. 284 (JSR) 194 United States v. Hes
, 58 United States v. Corr, 543 F.2d 1042 (2d Cir. 1976) 121 United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 40, 41 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 106 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 52 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N
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
United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996) 75 United States v. D'Amico, 734 F. Supp. 2d 321 (S.D.N.Y.
v. Corr, 543 F.2d 1042 (2d Cir. 1976) 181 xii EFTA00103011 United States v. Countentos, 651 F.3d 809 (8th Cir. 2011) 57, 58 United States v. Cromitie, 727 F.3d 194 (2d Cir. 2019) 154 United States v. Cromitie, et al., 09 Cr. 558 (CM) 286 United States v. Crouch, 84 F.3d 1497 (5th Cir. 1996)
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,
guarantees of due process." United States v. Heyward, No. 10 Cr. 84 (LTS), 2010 WL 4484642, at *3 (S.D.N.Y. Nov. 9, 2010); see also United States v. Cromitie, 727 F.3d 194, 218 (2d Cir. 2019). There also "must be a causal connection between the violation and the deprivation of the defendant's life or li
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,
guarantees of due process." United States v. Heyward, No. 10 Cr. 84 (LTS), 2010 WL 4484642, at *3 (S.D.N.Y. Nov. 9, 2010); see also United States v. Cromitie, 727 F.3d 194, 218 (2d Cir. 2019). There also "must be a causal connection between the violation and the deprivation of the defendant's life or li
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,
guarantees of due process." United States v. Heyward, No. 10 Cr. 84 (LTS), 2010 WL 4484642, at *3 (S.D.N.Y. Nov. 9, 2010); see also United States v. Cromitie, 727 F.3d 194, 218 (2d Cir. 2019). There also "must be a causal connection between the violation and the deprivation of the defendant's life or li
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,
guarantees of due process." United States v. Heyward, No. 10 Cr. 84 (LTS), 2010 WL 4484642, at *3 (S.D.N.Y. Nov. 9, 2010); see also United States v. Cromitie, 727 F.3d 194, 218 (2d Cir. 2019). There also "must be a causal connection between the violation and the deprivation of the defendant's life or li
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,
guarantees of due process." United States v. Heyward, No. 10 Cr. 84 (LTS), 2010 WL 4484642, at *3 (S.D.N.Y. Nov. 9, 2010); see also United States v. Cromitie, 727 F.3d 194, 218 (2d Cir. 2019). There also "must be a causal connection between the violation and the deprivation of the defendant's life or li
Entities connected to both the Southern District and Cromitie

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