Epstein Secrets

United States v. Myers, 692 F.2d 823 (2d Cir. 1982) 153, 161 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 241 United States v. Nejad, No. 18 Cr. 224 (AJN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nersesian, 824 F.2d 1294 (2d Cir. 1987) 233 EFTA00099959

152 VIII. There Is No Basis to Strike Any Portion of the Indictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as '\lultiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. Th

Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975)). As such, "[a] defendant faces a high standard in seeking to dismiss an indictment." United States v. Nejad,No. 18 Cr. 224 (AJN), 2019 WL 6702361, at *3 (S.D.N.Y. Dec. 9, 2019) (internal quotation marks omitted) (quoting United States v. Post, 950 F. Supp.

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they am m

United States v. Myers, 692 F.2d 823 (2d Cir. 1982) 153, 161 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 241 United States v. Nejad, No. 18 Cr. 224 (MN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA000776

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975)). As such, "[a] defendant faces a high standard in seeking to dismiss an indictment." United States v. Nejad, No. 18 Cr. 224 (MN), 2019 WL 6702361, at *3 (S.D.N.Y. Dec. 9, 2019) (internal quotation marks omitted) (quoting United States v. Post, 950 F. Supp.

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are

United States v. Myers, 692 F.2d 823 (2d Cir. 1982) 153, 161 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 241 United States v. Nejad, No. 18 Cr. 224 (MN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA000394

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975)). As such, "[a] defendant faces a high standard in seeking to dismiss an indictment." United States v. Nejad, No. 18 Cr. 224 (MN), 2019 WL 6702361, at *3 (S.D.N.Y. Dec. 9, 2019) (internal quotation marks omitted) (quoting United States v. Post, 950 F. Supp.

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are

United States v. Myers, 692 F.2d 823 (2d Cir. 1982) 105, 110 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 159 United States v. Nejad, 18 Cr. 224 (AJN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 150 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 154 United States v. Nit

limitations set forth in § 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

3 F.2d 1087, 1113 (2d Cir. 1975)). Given this standard, "[a] defendant faces a high standard in seeking to dismiss an indictment." United States v. Nejad, 18 Cr. 224 (AJN), 2019 WL 6702361, at *3 (S.D.N.Y. Dec. 9, 2019) (internal quotation marks omitted) (quoting Untied States v. Post, 950 F. Supp. 2d

ree and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. 168 EFTA00095260 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are

United States v. Myers, 692 F.2d 823 (2d Cir. 1982) 153, 161 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 241 United States v. Nejad, No. 18 Cr. 224 (MN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nersesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA00103

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975)). As such, "[a] defendant faces a high standard in seeking to dismiss an indictment." United States v. Nejad, No. 18 Cr. 224 (AJN), 2019 WL 6702361, at *3 (S.D.N.Y. Dec. 9, 2019) (internal quotation marks omitted) (quoting United States v. Post, 950 F. Supp

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are