Epstein Secrets

No. 09 Cr. 1184 (RJH), 2010 WL 4867402 (S.D.N.Y. Nov. 24, 2010) 172 United States v. Ramnath, 131 F.3d 132 (2d Cir. 1997) 300 United States v. Raymonda, 780 F.3d 105 (2d Cir. 2015) 124 United States v. Reeves, et al., 16 Cr. 372 (VEC) 286 United States v. Remington, 208 F.2d 567 (2d Cir. 1953

152 VIII. There Is No Basis to Strike Any Portion of the Indictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as '\lultiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. Th

e used only where law enforcement "`exhibit[s] deliberate, reckless, or grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they am m

No. 09 Cr. 1184 (RJH), 2010 WL 4867402 (S.D.N.Y. Nov. 24, 2010) 172 United States v. Ramnath, 131 F.3d 132 (2d Cir. 1997) 300 United States v. Raymonda, 780 F.3d 105 (2d Cir. 2015) 124 United States v. Reeves, et al., 16 Cr. 372 (VEC) 286 United States v. Remington, 208 F.2d 567 (2d Cir. 1953)

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

e used only where law enforcement "`exhibit[s] deliberate, reckless, or grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are

No. 09 Cr. 1184 (RJH), 2010 WL 4867402 (S.D.N.Y. Nov. 24, 2010) 172 United States v. Ramnath, 131 F.3d 132 (2d Cir. 1997) 300 United States v. Raymonda, 780 F.3d 105 (2d Cir. 2015) 124 United States v. Reeves, et al., 16 Cr. 372 (VEC) 286 United States v. Remington, 208 F.2d 567 (2d Cir. 1953)

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

e used only where law enforcement "`exhibit[s] deliberate, reckless, or grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are

No. 09 Cr. 1184 (RJH), 2010 WL 4867402 (S.D.N.Y. Nov. 24, 2010) 116 United States v. Ramnath, 131 F.3d 132 (2d Cir. 1997) 208 United States v. Raymonda, 780 F.3d 105 (2d Cir. 2015) 87 United States v. Remington, 208 F.2d 567 (2d Cir. 1953) 101 United States v. Resendiz-Ponce, 549 U.S. 102 (200

limitations set forth in § 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

e used only where law enforcement "`exhibit[s] deliberate, reckless, or grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d

ree and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. 168 EFTA00095260 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are

No. 09 Cr. 1184 (RJH), 2010 WL 4867402 (S.D.N.Y. Nov. 24, 2010) 172 United States v. Ramnath, 131 F.3d 132 (2d Cir. 1997) 300 United States v. Raymonda, 780 F.3d 105 (2d Cir. 2015) 124 United States v. Reeves, et al., 16 Cr. 372 (VEC) 286 United States v. Remington, 208 F.2d 567 (2d Cir. 1953

ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed

e used only where law enforcement "`exhibit[s] deliberate, reckless, or grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d

in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are