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681 (1988) 5, 6 Salinas v. United States, 522 U.S. 52 (1997) 8 United States v. Bagaric, 706 F.2d 42 (2d Cir. 1983) 6, 7, 8 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), of 'd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 8 United States v. Carboni, 204 F.3
n the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal ag
OF AUTHORITIES Page(s) Cases Grunewald v. United States, 353 U.S. 391 (1957) 8 Stogner v. California, 539 U.S. 607 (2003) 7 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), affd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 7 United States v. Curley, 639 F.3d
g), 108 Stat. 1796 6 iii EFTA00086739 PRELIMINARY STATEMENT Ghislaine Maxwell respectfully submits this Memorandum in Support of her Motion to Strike Surplusage from the Indictment ("Motion"). Although Ms. Maxwell is charged with conspiring to cause individuals to travel in interstate or foreign commerce to
681 (1988) 5, 6 Salinas v. United States, 522 U.S. 52 (1997) 8 United States v. Bagaric, 706 F.2d 42 (2d Cir. 1983) 6, 7, 8 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002), of 'd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 8 United States v. Carboni, 204 F.3
n the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal ag
Entities connected to both Benussi and Strike Surplusage

Ghislaine Maxwell
PERSON
United States
LOCATION
Southern District of New York
ORGANIZATION
Jeffrey Epstein
PERSONConcepcion
PERSONSalinas
PERSONPascarella
PERSON
Figueroa
PERSONSliker
PERSONHuddleston
PERSONJeffrey Pagliuca
PERSON
Prince Andrew
PERSONGrunewald v. United States
LOCATION
United Kingdom
LOCATION
John F. Kennedy
PERSONSalmonese
PERSONR. Everdell
PERSON
Michael Cohen
PERSONMann Act
PERSON
Christian Everdell
PERSON