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that the government was considering any charging decisions against Ms. Maxwell. We were never given that opportunity, which is uncharacteristic for the Southern District of New York, nor were we given any notice of her impending arrest. 22 EFTA00065743 The government argued to the Court that defense counsel's con
ns to the Court regarding the strength of its case. See, e.g., United States v. Stephens, 447 F. Supp. 3d 63, 65 (S.D.N.Y. 2020) 7 EFTA00065728 (Nathan, J.) (reconsidering bail decision based, in part, on evidence suggesting government's case weaker than alleged at initial hearing and concern about poss
that the government was considering any charging decisions against Ms. Maxwell. We were never given that opportunity, which is uncharacteristic for the Southern District of New York, nor were we given any notice of her impending arrest. 22 EFTA00154539 The government argued to the Court that defense counsel's con
ns to the Court regarding the strength of its case. See, e.g., United States v. Stephens, 447 F. Supp. 3d 63, 65 (S.D.N.Y. 2020) 7 EFTA00154524 (Nathan, J.) (reconsidering bail decision based, in part, on evidence suggesting government's case weaker than alleged at initial hearing and concern about poss
lements. See Letter from L. Mennin er to Hon. Debra C. Freeman at 2-3, ECF No. 108 (accusing of "working during the pendency of this lawsuit with the Southern District of New York's U.S. Attorney's Office to try to circumvent Ms. Maxwell's Fifth Amendment rights in advance of the June 29, 2020 indictment"); id. at
to trial to obtain materials usable only to impeach." United States v. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016) (Nathan, J.) (granting motion to quash Rule 17(c) subpoena for all records relating to cooperating witnesses); see also Nixon, 418 U.S. at 701 ("Generally, the
that the government was considering any charging decisions against Ms. Maxwell. We were never given that opportunity, which is uncharacteristic for the Southern District of New York, nor were we given any notice of her impending arrest. 22 EFTA00094316 The government argued to the Court that defense counsel's con
ns to the Court regarding the strength of its case. See, e.g., United States v. Stephens, 447 F. Supp. 3d 63, 65 (S.D.N.Y. 2020) 7 EFTA00094301 (Nathan, J.) (reconsidering bail decision based, in part, on evidence suggesting government's case weaker than alleged at initial hearing and concern about poss
that the government was considering any charging decisions against Ms. Maxwell. We were never given that opportunity, which is uncharacteristic for the Southern District of New York, nor were we given any notice of her impending arrest. 22 EFTA00093243
tes v. Stephens, 447 F. Supp. 3d 63, 65 (S.D.N.Y. 2020) 7 EFTA00093228 C6sel.211-Z7400304,AStilit Mitifisktit19102Frii (1231W2F3aF:45 IA at 45 (Nathan, J.) (reconsidering bail decision based, in part, on evidence suggesting government's case weaker than alleged at initial hearing and concern about poss
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,
ecise an identity between the character of the offenses!" United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 138 EFTA00100105 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the 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,
ecise an identity between the character of the offenses!" United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 138 EFTA00077770 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the 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,
ecise an identity between the character of the offenses!" United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 138 EFTA00039585 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the c
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,
ecise an identity between the character of the offenses!" United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the counts have a suffici
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,
cise an identity between the character of the offenses."' United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 138 EFTA00103163 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the c
Entities connected to both the Southern District and Nathan, J.

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
New York
LOCATION
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Palm Beach
LOCATION
Stephen Hawking
PERSON
George Mitchell
PERSON
Supreme Court
ORGANIZATION
Michael Jackson
PERSON