Epstein Secrets

.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SJF) (AYS), 2019 WL 3072288 (E.D.N.Y. July 15, 2019) 86 United States v. Dumitru, No. 18 Cr. 243 (LAK), 2018 WL 3407703 (S.D.N.Y. June 26, 2018) 261 United States v. Eldred, 933 F.3

bit 3: Exhibit 4: Exhibit 5: Exhibit 6: Exhibit 7: Exhibit 8: Exhibit 9: Exhibit 10: Exhibit 11: Exhibit 12: Notes from the U.S. Attorney's Office for the Southern District of New York June 14, 2007 Email November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Notes from February 11, 2021 Call Note

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. 1). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

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

F. Supp. 2d 590 (S.D.N.Y. 2008) 151 United States v. Ash, 464 F. Supp. 3d 621 (S.D.N.Y. 2020) 145 United States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United Sta

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. I). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

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

F. Supp. 2d 590 (S.D.N.Y. 2008) 151 United States v. Ash, 464 F. Supp. 3d 621 (S.D.N.Y. 2020) 145 United States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United Sta

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. I). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

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

WL 5090039 (S.D.N.Y. Oct. 10, 2014) 83 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 18, 19 2016 WL 1055737 (S.D.N.Y. Mar. 10, 2016) 2019 WL 3072288 (E.D.N.Y. July 15, 2019) 2020 WL 3483702 (S.D.N.Y. June 26, 2020) 2021 WL 78235 (January 11, 2021) Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Se

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and her name is not

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

311 (E.D.N.Y. 2016) 7 United States v. Bunn, 154 F. App'x 227 (2d Cir. 2005) 237 United States v. Burke, No. 09 Cr. 135 (SJ), 2011 WL 2609837 (E.D.N.Y. July 1, 2011) 82 United States v. Butler, 351 F. Supp. 121 (S.D.N.Y. 2004) 243 United States v. Butler, No. 04 Cr. 340, 2004 WL 2274751 (S.D.N.

ase The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA") between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida (the "USAO-SDFL"). (Def. Mot. 1). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and

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

er for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[t]he law in this circuit clearly supports the joinder of

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

er for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[t]he law in this circuit clearly supports the joinder of

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

er for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[t]he law in this circuit clearly supports the joinder of

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

er for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "Nile law in this circuit clearly supports the joinder of

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

er for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[t]he law in this circuit clearly supports the joinder of

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