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8) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 21, 26 United States v. Lovasco, 431 U.S. 783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (AJN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 Unit
er necessary element to prevail: that the claimed delay by the Government was intentional and deliberate to gain a strategic advantage. Here, as in Lovasco, any pre-indictment delay was the result of the Government's continuing investigation of the case. The Lovasco Court held that the investigative de
nses, none of which are contained in the Indictment. As a result, the defendant cannot invoke the NPA to seek the dismissal of the Indictment. 2. The NPA Does Not Confer Enforceable Rights on Maxwell Even if this Court were to construe the NPA beyond its plain terms to preclude prosecutions for the c
8) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 21, 26 United States v. Lovasco, 431 U.S. 783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 Unite
ndant could establish any actual prejudice—which she cannot—such prejudice would be "necessary but not sufficient" to establish a due process claim. Lovasco, 431 U.S. at 790. The defendant's motion fails because she has not demonstrated the other necessary element to prevail: that the claimed delay by t
nses, none of which are contained in the Indictment. As a result, the defendant cannot invoke the NPA to seek the dismissal of the Indictment. 2. The NPA Does Not Confer Enforceable Rights on Maxwell Even if this Court were to construe the NPA beyond its plain terms to preclude prosecutions for the c
8) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 21, 26 United States v. Lovasco, 431 U.S. 783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 Unite
ndant could establish any actual prejudice—which she cannot—such prejudice would be "necessary but not sufficient" to establish a due process claim. Lovasco, 431 U.S. at 790. The defendant's motion fails because she has not demonstrated the other necessary element to prevail: that the claimed delay by t
nses, none of which are contained in the Indictment. As a result, the defendant cannot invoke the NPA to seek the dismissal of the Indictment. 2. The NPA Does Not Confer Enforceable Rights on Maxwell Even if this Court were to construe the NPA beyond its plain terms to preclude prosecutions for the c
8) 105 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 45 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 18, 21 United States v. Lovasco, 431 U.S. 783 (1977) 52, 53, 54, 55 United States v. Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 174, 176, 177 United S
ndant could establish any actual prejudice—which she cannot—such prejudice would be "necessary but not sufficient" to establish a due process claim. Lovasco, 431 53 EFTA00095145 U.S. at 790. The defendant's motion fails because she has not demonstrated the other necessary element to prevail: that the
nses, none of which are contained in the Indictment. As a result, the defendant cannot invoke the NPA to seek the dismissal of the Indictment. 2. The NPA Does Not Confer Enforceable Rights On Maxwell Even if this Court were to construe the NPA beyond its plain terms to preclude prosecutions for the c
) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 21, 26 United States v. Lovasco, 431 U.S. 783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 Unite
ndant could establish any actual prejudice—which she cannot—such prejudice would be "necessary but not sufficient" to establish a due process claim. Lovasco, 431 U.S. at 790. The defendant's motion fails because she has not demonstrated the other necessary element to prevail: that the claimed delay by t
nses, none of which are contained in the Indictment. As a result, the defendant cannot invoke the NPA to seek the dismissal of the Indictment. 2. The NPA Does Not Confer Enforceable Rights on Maxwell Even if this Court were to construe the NPA beyond its plain terms to preclude prosecutions for the c
Entities connected to both Lovasco and The NPA

Julie K. Brown
PERSONDornau
PERSON
United States
LOCATIONChacko
PERSONJoe Recarey
PERSON
Michael Jackson
PERSON
Scarlett Johansson
PERSON
Hernandez
PERSON
Ghislaine Maxwell
PERSON
Cornell University
ORGANIZATION
Kaplan
PERSON
Jennifer Lopez
PERSONEstrada
ORGANIZATIONSnyder
PERSON
Lawson
PERSONBirney
PERSONMichael Casey
PERSON
Jeffrey Epstein
PERSONSalameh
PERSONDarren Indyke
PERSON