Epstein Secrets

torneys representing plaintiffs in civil litigation against Ms. Maxwell met with a section chief in the United States Attorney's Office ("USAO") for the Southern District of New York ("SDNY") and pitched the idea of bringing a criminal case against Ms. Maxwell for conduct similar, if not identical, to that alleged in

00065990 TABLE OF AUTHORITIES Page(s) Cases Advani Enters., Inc. v. Underwriters at Lloyds, 140 F.3d 157 (2d Cir. 1998) 23 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (I I th Cir. 2005) 15 Own St v. Street Beat Sportswear; Inc., 226 F. Supp. 2d 355 (E.D.N.Y. 2002) 15 Crutsinger v. Hess, 408 F.

torneys representing plaintiffs in civil litigation against Ms. Maxwell met with I section chief in the United States Attorney's Office ("USAO") for the Southern District of New York ("SDNY") and pitched the idea of bringing I criminal case against Ms. Maxwell for conduct similar, if not identical, to that alleged in

00099353 TABLE OF AUTHORITIES Page(s) Cases Advani Enters., Inc. v. Underwriters at Lloyds, 140 F.3d 157 (2d Cir. 1998) 23 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (I I th Cir. 2005) 15 Own St v. Street Beat Sportswear; Inc., 226 F. Supp. 2d 355 (E.D.N.Y. 2002) 15 Crutsinger v. Hess, 408 F.

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

aszczak, 17 Cr. 357 (LAK) 275 Nissen v. Lefevre, 924 F.2d 434 (2d Cir. 1991) 158 Mum v. Yaretsky, 457 U.S. 991 (1982) 143 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (11th Cir. 2005) 24 Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 148 Boyd

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

czak, 17 Cr. 357 (LAK) 275 Blissett v. Lefevre, 924 F.2d 434 (2d Cir. 1991) 158 Blum v. Yaretsky, 457 U.S. 991 (1982) 143 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (11th Cir. 2005) 24 Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 148 Boyd

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

czak, 17 Cr. 357 (LAK) 275 Blissett v. Lefevre, 924 F.2d 434 (2d Cir. 1991) 158 Blum v. Yaretsky, 457 U.S. 991 (1982) 143 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (11th Cir. 2005) 24 Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 148 Boyd

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

559 U.S. 314 (2010) 207, 210 Blissett v. Lefevre, 924 F.2d 434 (2d Cir. 1991) 108 Blum v. Yaretsky, 457 U.S. 991 (1982) 99 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (11th Cir. 2005) 20 Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 102 Boyd

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

czak, 17 Cr. 357 (LAK) 275 Blissett v. Lefevre, 924 F.2d 434 (2d Cir. 1991) 158 Blum v. Yaretsky, 457 U.S. 991 (1982) 143 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (11th Cir. 2005) 24 Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 148 Boyd