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"no one characteristic is always sufficient to establish 'similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
"no one characteristic is always sufficient to establish `similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
"no one characteristic is always sufficient to establish `similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
"no one characteristic is always sufficient to establish `similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980
rt that the defendant "had not engaged in any business activity during the preceding six years").54 Accordingly, and consistent with the holding in Ruiz and Broccolo, this Court should deny the severance motion. 54 While the defendant may argue that the fact that her deposition, unlike Ruiz, did not involve crim
"no one characteristic is always sufficient to establish `similarity' of offenses, and each case depends largely on its own facts." United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
Entities connected to both Blakney and Ruiz and Broccolo

United States
LOCATIONWerner
PERSONJeffrey Pagliuca
PERSON
Ghislaine Maxwell
PERSONPotamitis
PERSONJoinder
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Jeffrey Epstein
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New Mexico
LOCATION
Julie K. Brown
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Martinez
PERSONSweet
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Michael Jackson
PERSON
Rivera
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Medicaid
ORGANIZATIONSampson
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Hastings
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Figueroa
PERSON
Jennings
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Supreme Court
ORGANIZATION
North Carolina
LOCATION