Epstein Secrets

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 &

eopardy Clause 18 III. Counts Five and Six Are Time-Barred. 20 IV. The Court Should Dismiss Count Five and Either Count One or Count Three as Multiplicitous 21 V. The Court Should Dismiss the S2 Indictment for Pre-Indictment Delay. 22 VI. The Court Should Order a Bill of Particulars as to Counts Fiv

lease contact us with any questions. Your consideration is greatly appreciated. Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York New York 10022 cc: All counsel of record (via email) EFTA00095655

h Six of the Superseding Indictment for Pre- Indictment Delay 8. Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous 9. Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment 10. Motion for a Bill of Particulars and Pr

with proposed redactions. Please contact us with any questions. Your consideration is greatly appreciated. Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP cc: All counsel of record (via email) For documents that the government has designated as "Confidentia

tment for Pre-Indictment Delay 8. Reply Memorandum in Support of Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous 9. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment 10. Reply Me