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ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
222 United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 284 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 48 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 155 United States v. Ghavami, No. 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 262 United S
Government is prepared to address any questions the Court may have or to provide any additional information upon request. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: Ill Assistant United States Attorneys Southern District of New York Tel: Cc: counsel of record, via ECF EF
te to AUSAs knowledge of reports prepared by FBI agents who were "uninvolved in the investigation or trial of the defendants"); cf. United States v. Ghailani, 687 F. Supp. 2d 365, 372 (S.D.N.Y. 2010) (holding that, in the context of a speedy trial motion, other members of the Department of Justice who we
Government is prepared to address any questions the Court may have or to provide any additional information upon request. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: Cc: All counsel of record, via ECF Assistant United States Attorneys Southern District of New York Tel: EFT
te to AUSAs knowledge of reports prepared by FBI agents who were "uninvolved in the investigation or trial of the defendants"); cf. United States v. Ghailani, 687 F. Supp. 2d 365, 372 (S.D.N.Y. 2010) (holding that, in the context of a speedy trial motion, other members of the Department of Justice who we
Government is prepared to address any questions the Court may have or to provide any additional information upon request. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: Cc: All counsel of record, via ECF Assistant United States Attorneys Southern District of New York Tel: EFT
te to AUSAs knowledge of reports prepared by FBI agents who were "uninvolved in the investigation or trial of the defendants"); cf. United States v. Ghailani, 687 F. Supp. 2d 365, 372 (S.D.N.Y. 2010) (holding that, in the context of a speedy trial motion, other members of the Department of Justice who we
Government is prepared to address any questions the Court may have or to provide any additional information upon request. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: / Assistant United States Attorneys Southern District of New York Tel: Cc: All counsel of record, via ECF
te to AUSAs knowledge of reports prepared by FBI agents who were "uninvolved in the investigation or trial of the defendants"); cf. United States v. Ghailani, 687 F. Supp. 2d 365, 372 (S.D.N.Y. 2010) (holding that, in the context of a speedy trial motion, other members of the Department of Justice who we
Government is prepared to address any questions the Court may have or to provide any additional information upon request. Respectfully submitted, AUDREY STRAUSS Acting United States Attorney By: Cc: All counsel of record, via ECF / / Assistant United States Attorneys Southern District of New York Tel
te to AUSAs knowledge of reports prepared by FBI agents who were "uninvolved in the investigation or trial of the defendants"); cf. United States v. Ghailani, 687 F. Supp. 2d 365, 372 (S.D.N.Y. 2010) (holding that, in the context of a speedy trial motion, other members of the Department of Justice who we
ICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
,222 United States v. Geanev, 417 F.2d 1116 (2d Cir. 1969) 284 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 48 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 155 United States v. Ghavami, No. 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 262 United
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
222 United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 284 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 48 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 155 United States v. Ghavami, No. 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 262 United S
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
222 United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 284 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 48 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 155 United States v. Ghavami, No. 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 262 United S
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 191 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 35, 36 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 106 United States v. Ghavami, 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 171 United State
Entities connected to both Audrey Strauss and Ghailani

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Ghislaine Maxwell
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Prince Andrew
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Department of Justice
ORGANIZATIONthe Southern District
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George W. Bush
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ORGANIZATIONJeffrey Pagliuca
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Martha Stewart
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Julie K. Brown
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