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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
ucky, 448 U.S. 98 (1980) Richardson v. Marsh, 165 116 481 U.S. 200 (1987) 212 Rivera v. United States, 928 F.2d 592 (2d Cir. 1991) 168, 172 Rochin, 342 U.S., 72 S. Ct. 205 153 Rosencrans v. United States, 165 U.S. 257 (1897) 296 Russell v. United States, 369 U.S. 749 (1962) 229 Rutenber
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,
ed). The Second Circuit has explained: The paradigm examples of conscience-shocking conduct am egregious invasions of individual rights. See, e.g., Rochin, 342 U.S. at 172, 72 S. Ct. 205 (breaking into suspect's bedroom, forcibly attempting to pull capsules from his throat, and pumping his stomach wi
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
Kentucky, 448 U.S. 98 (1980) 116 Richardson v. Marsh, 481 U.S. 200 (1987) 212 Rivera v. United States, 928 F.2d 592 (2d Cir. 1991) 168, 172 Rochin, 342 U.S., 72 S. Ct. 205 153 Rosencrans v. United States, 165 U.S. 257 (1897) 296 Russell v. United States, 369 U.S. 749 (1962) 229 Rutenber
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,
d). The Second Circuit has explained: The paradigm examples of conscience-shocking conduct are egregious invasions of individual rights. See, e.g., Rochin, 342 U.S. at 172, 72 S. Ct. 205 (breaking into suspect's bedroom, forcibly attempting to pull capsules from his throat, and pumping his stomach wi
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
Kentucky, 448 U.S. 98 (1980) 116 Richardson v. Marsh, 481 U.S. 200 (1987) 212 Rivera v. United States, 928 F.2d 592 (2d Cir. 1991) 168, 172 Rochin, 342 U.S., 72 S. Ct. 205 153 Rosencrans v. United States, 165 U.S. 257 (1897) 296 Russell v. United States, 369 U.S. 749 (1962) 229 Rutenber
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,
d). The Second Circuit has explained: The paradigm examples of conscience-shocking conduct are egregious invasions of individual rights. See, e.g., Rochin, 342 U.S. at 172, 72 S. Ct. 205 (breaking into suspect's bedroom, forcibly attempting to pull capsules from his throat, and pumping his stomach wi
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
. Kentucky, 448 U.S. 98 (1980) 83 Richardson v. Marsh, 481 U.S. 200 (1987) 142 Rivera v. United States, 928 F.2d 592 (2d Cir. 1991) 114, 116 Rochin, 342 U.S., 72 S. Ct. 205 105 Rosencrans v. United States, 165 U.S. 257 (1897) 203 Russell v. United States, 369 U.S. 749 (1962) 151 Rutenber
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,
). The Second Circuit has explained: The paradigm examples of conscience-shocking conduct are egregious invasions of individual rights. See, e.g., Rochin, 342 U.S. at 172, 72 S. Ct. 205 (breaking into suspect's bedroom, forcibly attempting to pull capsules from his throat, and pumping his stomach wi
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
Kentucky, 448 U.S. 98 (1980) 116 Richardson v. Marsh, 481 U.S. 200 (1987) 212 Rivera v. United States, 928 F.2d 592 (2d Cir. 1991) 168, 172 Rochin, 342 U.S., 72 S. Ct. 205 153 Rosencrans v. United States, 165 U.S. 257 (1897) 296 Russell v. United States, 369 U.S. 749 (1962) 229 Rutenber
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,
d). The Second Circuit has explained: The paradigm examples of conscience-shocking conduct are egregious invasions of individual rights. See, e.g., Rochin, 342 U.S. at 172, 72 S. Ct. 205 (breaking into suspect's bedroom, forcibly attempting to pull capsules from his throat, and pumping his stomach wi
Entities connected to both the Southern District and Rochin

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