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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
0 United States v. Dewar, 489 F. Supp. 2d 351 (S.D.N.Y. 2007) 165 United States v. Diaz, 176 F.3d 52 (2d Cir. 1999) 251, 253 United States v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 155 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en bane) 54 United States v. Dornau, 356 F. Sup
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,
is warranted only where the Government's behavior "resulted in [] prejudice to the [defendant's] defense or legal representation." United States v. DiGregorio, 795 F. Supp. 630, 635 (S.D.N.Y. 1992). Absent a showing of prejudice, the appropriate remedy for conduct violating the test for outrageousness is
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
50 United States v. Dewar, 489 F. Supp. 2d 351 (S.D.N.Y. 2007) 165 United States v. Diaz, 176 F.3d 52 (2d Cir. 1999) 251, 253 United States v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 155 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en banc) 54 United States v. Dornau, 356 F. Supp
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,
is warranted only where the Government's behavior "resulted in [] prejudice to the [defendant's] defense or legal representation." United States v. DiGregorio, 795 F. Supp. 630, 635 (S.D.N.Y. 1992). Absent a showing of prejudice, the appropriate remedy for conduct violating the test for outrageousness is
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
50 United States v. Dewar, 489 F. Supp. 2d 351 (S.D.N.Y. 2007) 165 United States v. Diaz, 176 F.3d 52 (2d Cir. 1999) 251, 253 United States v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 155 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en banc) 54 United States v. Dornau, 356 F. Supp
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,
is warranted only where the Government's behavior "resulted in [] prejudice to the [defendant's] defense or legal representation." United States v. DiGregorio, 795 F. Supp. 630, 635 (S.D.N.Y. 1992). Absent a showing of prejudice, the appropriate remedy for conduct violating the test for outrageousness is
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
64 United States v. Dewar, 489 F. Supp. 2d 351 (S.D.N.Y. 2007) 112 United States v. Diaz, 176 F.3d 52 (2d Cir. 1999) 165, 166 United States v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 106 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) 39 United States v. Dornau, 356 F. Supp. 1091 (S.
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,
is warranted only where the Government's behavior "resulted in [] prejudice to the [defendant's] defense or legal representation." United States v. DiGregorio, 795 F. Supp. 630, 635 (S.D.N.Y. 1992). Absent a showing of prejudice, the appropriate remedy for conduct violating the test for outrageousness is
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
50 United States v. Dewar, 489 F. Supp. 2d 351 (S.D.N.Y. 2007) 165 United States v. Diaz, 176 F.3d 52 (2d Cir. 1999) 251, 253 United States v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 155 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en banc) 54 United States v. Dornau, 356 F. Sup
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,
is warranted only where the Government's behavior "resulted in [] prejudice to the [defendant's] defense or legal representation." United States v. DiGregorio, 795 F. Supp. 630, 635 (S.D.N.Y. 1992). Absent a showing of prejudice, the appropriate remedy for conduct violating the test for outrageousness is
Entities connected to both the Southern District and DiGregorio

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
PERSON
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
A. Marie Villafana
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Ken Starr
PERSON
Palm Beach
LOCATION
Stephen Hawking
PERSON