Epstein Secrets

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

12 United States v. Anderson, 772 F.3d 969 (2d Cir. 2014) 162 United States v. Annabi, 10 Cr. 07 (CM) 286 ix EFTA00099950 United States v. Annahi, 771 F.2d 670 (2d Cir. 1985) 5, 7, 8 United States v. Annahi, 771 F.2d 670 (2d Cir. 1985), alrd, 867 F.2d 1425 (2d Cir. 1988) 5 United States v

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

bind other districts. To the contrary, there are affirmative indications in the text that the NPA applies only to the USAO-SDFL. Accordingly, under Annahi, the NPA is only binding on the USAO-SDFL, and the defendant's motion fails as a matter of law. 2. The Defendant Has Offered No Evidence That the

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

bind other districts. To the contrary, there are affirmative indications in the text that the NPA applies only to the USAO-SDFL. Accordingly, under Annahi, the NPA is only binding on the USAO-SDFL, and the defendant's motion fails as a matter of law. 2. The Defendant Has Offered No Evidence That the