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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
07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 269 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Saftar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 27 United States v. Savage, 970 F.3d 217
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,
w being questioned in his role as trustee." 782 F.2d at 376. "[F]undamental ambiguity," however, "is the exception, not the rule." United States v. Sarwari, 669 F.3d 401, 407 (4th Cir. 2012) (quoting United States v. Farmer, 137 F.3d 1265, 1269 (10th Cir. 1998)). A defendant cannot demonstrate fundament
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
07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 269 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 27 United States v. Savage, 970 F.3d 217 (
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,
w being questioned in his role as trustee." 782 F.2d at 376. "[F]undamental ambiguity," however, "is the exception, not the rule." United States v. Sarwari, 669 F.3d 401, 407 (4th Cir. 2012) (quoting United States v. Fanner, 137 F.3d 1265, 1269 (10th Cir. 1998)). A defendant cannot demonstrate fundament
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
07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 269 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 27 United States v. Savage, 970 F.3d 217 (
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,
w being questioned in his role as trustee." 782 F.2d at 376. "[F]undamental ambiguity," however, "is the exception, not the rule." United States v. Sarwari, 669 F.3d 401, 407 (4th Cir. 2012) (quoting United States v. Fanner, 137 F.3d 1265, 1269 (10th Cir. 1998)). A defendant cannot demonstrate fundament
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
07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 177 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 52 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 120, 121 United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 22 United States v. Savage, 970 F.3d 217 (
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,
ow being questioned in his role as trustee." 782 F.2d at 376. "[F]undamental ambiguity," however, "is the exception, not the rule." United States v. Sarwari, 669 F.3d 401, 407 (4th Cir. 2012) (quoting United States v. Fanner, 137 F.3d 1265, 1269 (10th Cir. 1998)). A defendant cannot demonstrate fundamen
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
07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 269 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 27 United States v. Savage, 970 F.3d 217
Entities connected to both the Southern District and Sarwari

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