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ere arrested at Kennedy Airport on November 23, 1982, in possession of four kilograms of heroin and were charged in a three-count indictment in the Eastern District of New York with (I) conspiracy to import heroin into the United States, (2) a substantive offense of importing heroin, and (3) possession of heroin
he Double Jeopardy Clause, and (3) grant her other requested relief. Dated: May 7, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
s opinion that the defendants did not have a Double Jeopardy claim because they "were never in jeopardy with respect to the dismissed counts of the Eastern District indictment." Annabi, 771 F.2d at 671. The court was clear that the defendants' only claim on appeal was that the Southern District indictment "viol
ements as Brady material, and (4) grant her other requested relief. Dated: May 28, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue ISO Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East
); United States v. Ashraf, 320 F. App'x 26, 28 (2d Cir. 2009) (plea agreement "by its express terms, bound only the U.S. Attorney's Office for the Eastern District of Virginia"); Gonzalez, 93 F. App'x at 270 ("Paragraph 13 explicitly states that the agreement binds only the United States Attorney's Office for t
ANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim At
Entities connected to both Eastern District and R. Everdell

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
United States
LOCATIONJeffrey Pagliuca
PERSONCohen & Gresser LLP
ORGANIZATIONthe Southern District
LOCATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
Denver
LOCATIONSecond Circuit
ORGANIZATIONMORGAN & FOREMAN
ORGANIZATIONMark S. Cohen
PERSON
Department of Justice
ORGANIZATION
Stephen Hawking
PERSON
Colorado
LOCATIONLeon Black
PERSONSouthern District
LOCATION
Scarlett Johansson
PERSONEmmy Taylor
PERSON