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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.
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
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.
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
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.
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
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
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
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.
ivacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero's decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to vic
Entities connected to both Ruiz and Broccolo and Victor Marrero

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Ghislaine Maxwell
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Stephen Hawking
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David Boies
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