Epstein Secrets

States v. Prisco, 391 F. App'x 920 (2d Cir. 2010) 7 United States v. Rivera, 844 F.2d 916 (2d Cir. 1988) 9 ii EFTA00104413 United States v. Salamelz, 152 F.3d 88 (2d Cir. 1998) 7 United States v. Torres, 719 F.2d 549 (2d Cir. 1983) 15 iii EFTA00104414 Ghislaine Maxwell respectfully submit

ernment offers only one argument for why it should be permitted to prosecute Ms. Maxwell for these offenses. Relying on the Court's prior ruling and the Second Circuit's decision in United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) (per curiam), the government asserts that the NPA does not bind the U.S. Attorney'

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00040678 deliberatel

so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00106053 Case 1:20-c

so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Cap., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00066524 deliberatel

so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00087265 deliberatel

so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00087244 deliberatel

so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell

e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively

ircuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively extend the limitations period for still-viable pro

e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively

ircuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively extend the limitations period for still-viable pro

e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively

nited States v. Leo Sure Chief, 438 F.3d 920, 922-25 (9th Cir. 2006); United States v. Jeffiies, 405 F.3d 682, 685 (8th Cir. 2005). Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactively extend the limitations period for still-viable pr

e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively

rcuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief, 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactively extend the limitations period for still-viable pr