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Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
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2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
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2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
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2 mentions1 same-page
Page ?Same page
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
efendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to ma
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Prince Andrew
PERSON130 w/ The·11 w/ Artis
Department of Justice
ORGANIZATION124 w/ The·11 w/ Artis
Ghislaine Maxwell
PERSON84 w/ The·9 w/ Artis
the Southern District
LOCATION69 w/ The·11 w/ Artis
Jeffrey Epstein
PERSON62 w/ The·11 w/ Artis
Geoffrey S. Berman
PERSON53 w/ The·11 w/ Artis
United States
LOCATION31 w/ The·11 w/ Artis
Michael Cohen
PERSON31 w/ The·11 w/ Artis
FBI
ORGANIZATION30 w/ The·11 w/ Artis
Southern District of New York
ORGANIZATION26 w/ The·11 w/ Artis
U.S. Virgin Islands
LOCATION20 w/ The·11 w/ Artis
New York
LOCATION19 w/ The·11 w/ Artis
PI
Pitman
PERSON17 w/ The·11 w/ Artis
Amber Southerland
PERSON16 w/ The·11 w/ Artis
AN
Annabi
PERSON16 w/ The·11 w/ Artis
LA
Laskow
PERSON16 w/ The·11 w/ Artis
CA
Casteneda
PERSON16 w/ The·11 w/ Artis
PR
Prisco
PERSON16 w/ The·11 w/ Artis
N.Y. Post
ORGANIZATION16 w/ The·11 w/ Artis
Michael Jackson
PERSON16 w/ The·11 w/ Artis