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DNY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Del Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical 34 Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief J
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
DNY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Del Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical 34 Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief J
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
ranscript, no contact women_ the ant at nallavernment ongation. (Def. Mot. 3 at 1). Instead, ChiefJudgeltNahon's cAlgaismore specific: rearing Chemical figgrand desire to avoid "a Chemical Bank kind OREM5n," Chief Judge Mahon asked about cont between the two parties "prior to the issuance of the sub
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
NY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Def. Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief Judg
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
s investigation and the issuance of the subpoena. Additionally, and in light of the Government's prior arguments to Chief Judge McMahon relating to Chemical Bank,40 the Government attempted to address the misconduct at issue in that case: namely the production of confidential documents without seeking m
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
Entities connected to both Chemical and The Defendant's Motion

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Michael Jackson
PERSON
Eric Schmidt
PERSON
Bradley Edwards
PERSON
Adriana Ross
PERSON
David Boies
PERSONMaria Farmer
PERSON
Supreme Court
ORGANIZATIONthe Southern District
LOCATION
Michigan
LOCATION
Sacramento
LOCATION
Jenkins
PERSONMartindell
PERSON
Anderson
PERSON
Hastings
PERSON
Butler
PERSON