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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
, No. 11 Cr. 62 (PAC), 2013 WL 664712 (S.D.N.Y. Feb. 25, 2013) 267 United States v. Lighte, 782 F.2d 367 (2d Cir. 1986) passim United States v. Loera, 333 F. Supp. 3d 172 (E.D.N.Y. 2018) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st C
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,
dment due process rights, the government's method of acquiring the evidence must be so egregious that it `shocks the conscience.'" United States v. Loera, 333 F. Supp. 3d 172, 184 (E.D.N.Y. 2018) (internal quotation marks and citations omitted). "The concept of fairness embodied in the Fifth Amendmen
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
, No. II Cr. 62 (PAC), 2013 WL 664712 (S.D.N.Y. Feb. 25, 2013) 267 United States v. Lighte, 782 F.2d 367 (2d Cir. 1986) passim United States v. Loera, 333 F. Supp. 3d 172 (E.D.N.Y. 2018) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st C
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,
dment due process rights, the government's method of acquiring the evidence must be so egregious that it 'shocks the conscience.'" United States v. Loera, 333 F. Supp. 3d 172, 184 (E.D.N.Y. 2018) (internal quotation marks and citations omitted). "The concept of fairness embodied in the Fifth Amendme
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
, No. II Cr. 62 (PAC), 2013 WL 664712 (S.D.N.Y. Feb. 25, 2013) 267 United States v. Lighte, 782 F.2d 367 (2d Cir. 1986) passim United States v. Loera, 333 F. Supp. 3d 172 (E.D.N.Y. 2018) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st C
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,
dment due process rights, the government's method of acquiring the evidence must be so egregious that it 'shocks the conscience.'" United States v. Loera, 333 F. Supp. 3d 172, 184 (E.D.N.Y. 2018) (internal quotation marks and citations omitted). "The concept of fairness embodied in the Fifth Amendme
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
r. 62 (PAC), 2013 WL 664712 (S.D.N.Y. Feb. 25, 2013) 175 xv EFTA00095082 United States v. Lighte, 782 F.2d 367 (2d Cir. 1986) United States v. Loera, passim 333 F.Supp.3d 172 (E.D.N.Y. 2018) 105 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 45 United States v. Lopez, 944 F.2d 33
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,
dment due process rights, the government's method of acquiring the evidence must be so egregious that it 'shocks the conscience.'" United States v. Loera, 333 F.Supp.3d 172, 184 (E.D.N.Y. 2018) (internal quotation marks and citations omitted). "The concept of fairness embodied in the Fifth Amendment d
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
, No. II Cr. 62 (PAC), 2013 WL 664712 (S.D.N.Y. Feb. 25, 2013) 267 United States v. Lighte, 782 F.2d 367 (2d Cir. 1986) passim United States v. Loera, 333 F. Supp. 3d 172 (E.D.N.Y. 2018) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st C
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,
dment due process rights, the government's method of acquiring the evidence must be so egregious that it 'shocks the conscience.'" United States v. Loera, 333 F. Supp. 3d 172, 184 (E.D.N.Y. 2018) (internal quotation marks and citations omitted). "The concept of fairness embodied in the Fifth Amendmen
Entities connected to both the Southern District and Loera

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