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e terms) of the alleged crime" in order to be sufficient. United States v. Stavroulakis, 952 F.2d 686, 693 (2d Cir. 1992) (quoting United States v. 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
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
e terms) of the alleged crime" in order to be sufficient. United States v. Stavroulakis, 952 F.2d 686, 693 (2d Cir. 1992) (quoting United States v. 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, N
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
e terms) of the alleged crime" in order to be sufficient. United States v. Stavroulakis, 952 F.2d 686, 693 (2d Cir. 1992) (quoting United States v. 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, N
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
e terms) of the alleged crime" in order to be sufficient. United States v. Stavroulakis, 952 F.2d 686, 693 (2d Cir. 1992) (quoting United States v. Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975)). Given this standard, "[a] defendant faces a high standard in seeking to dismiss an indictment." United States
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
e terms) of the alleged crime" in order to be sufficient. United States v. Stavroulakis, 952 F.2d 686, 693 (2d Cir. 1992) (quoting United States v. 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, N
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
Entities connected to both Tramunti and Nitsche

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONNejad
PERSONThompson
PERSON
Napolitano
PERSONGaudin
PERSONWerner
PERSON
Medina
PERSONChacko
PERSONSampson
PERSON
Supreme Court
ORGANIZATIONMarkiewicz
PERSONForde
ORGANIZATIONConcepcion
PERSONMostafa
PERSONNersesian
PERSON
Scarlett Johansson
PERSON
Adriana Ross
PERSONthe Southern District
LOCATION