Epstein Secrets

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

84 In re Various Grand Jury Subpoenas, 924 F. Supp. 2d 549 (S.D.N.Y. 2013), afrd, 579 F. App'x 37 (2d Cir. 2014) 140 Intl Equity In vs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) .Johnson v. United States, 520 U.S. 461 (1997) 200 Kungvs v. United States

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,

government establishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. 36 See, e.g., Int'l Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n

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

84 In re Various Grand Jury Subpoenas, 924 F. Supp. 2d 549 (S.D.N.Y. 2013), aff'd, 579 F. App'x 37 (2d Cir. 2014) 140 Int'l Equity !nvs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 111 Johnson v. United States, 520 U.S. 461 (1997) 200 Kungys v. United St

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,

ound that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'! Equity Ines., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n

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

84 In re Various Grand Jury Subpoenas, 924 F. Supp. 2d 549 (S.D.N.Y. 2013), aff'd, 579 F. App'x 37 (2d Cir. 2014) 140 Int'l Equity !nvs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 111 Johnson v. United States, 520 U.S. 461 (1997) 200 Kungys v. United St

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,

ound that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'! Equity Ines., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n

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

re U.S., 834 F.2d 283 (2d Cir. 1987) 191 In re Various Grand Jury Subpoenas, 924 F. Supp. 2d 549 (S.D.N.Y. 2013) 98 Int'l Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 79 Johnson v. United States, 520 U.S. 461 (1997) 135 vi EFTA00095073 K

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,

elling need." Martindell, 594 F.3d at 296. [hat t l "Got ,[ 1 Sive publ hat in a a grad i jury esti 37 See, e.g., Lit'! Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n

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

284 In re Various Grand Amy Subpoenas, 924 F. Supp. 2d 549 (S.D.N.Y. 2013), aff'd, 579 F. App'x 37 (2d Cir. 2014) 140 Intl Equity !nvs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 111 Johnson v. United States, 520 U.S. 461 (1997) 200 Kungys v. United S

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,

found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant '6 See, e.g., Intl Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314, at *8 (S.D.N.Y. Mar. 2, 2010) (finding that the parties' reliance on a civil protective order "was n