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ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving a defendant who, despit
en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows a history that is both highly unusual and deeply troubling. The gov
ohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
tions omitted); Port Consol., Inc. v. Int'l Ins. Co. of Hannover, PLC, 826 F. App'x 822, 827 (11th Cir. 2020) (same under Florida law). The Justice Manual supports this view, admonishing prosecutors who do not wish to bind USAOs in other districts to "explicitly limit the scope" of the NPA to their dis
ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving I defendant who, despit
en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows I history that is both highly unusual and deeply troubling. The gov
overnment has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimat
tions omitted); Port Consol., Inc. v. Int'l Ins. Co. of Hannover, PLC, 826 F. App'x 822, 827 (11th Cir. 2020) (same under Florida law). The Justice Manual supports this view, admonishing prosecutors who do not wish to bind USAOs in other districts to "explicitly limit the scope" of the NPA to their dis
From: To: CC: Subject: HAPP program for GIV avionics Date: Tue, 14 May 2013 02:27:04 +0000 Jeffrey, I recommend we take advantage of enrollment in the HAPP (HoneyWell Avionic Protection Program) this program covers High dollar Honeywell equipment
o Bracket 1 $5,821 FZ-820 7003974-908 Flight Guidance Computer 2 $20,456 GP-820 7007546-902 Guidance Panel Controller 1 $16,633 PC-880 7007990-902 Manual Controller 1 $4,057 Flight Management AZ-810 7000700-964 Digital Air Data Computer 2 $17,495 PZ-800 7004609-930 Performance Computer 2 $19,494 CD
From: Jeffrey <jeevacationggmail.com> To: Richard Kahn Subject: Re: Manual Vacation Date: Wed, 02 May 2012 01:03:03 +0000 Take off Sorry for all the typos .Sen
> wrote: I had Una check with to make sure Manual did not have any time off this pay period that would affect his vacation hours due. Apparently, Manual has in fact been out since Thursday the 26th , Friday 27th (holiday), 30th Monday and 1st Tuesday. He is in PR visiting his sister who has She expe
Entities connected to both Jeffrey Epstein and Manual

Ghislaine Maxwell
PERSON
United States
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
New York
LOCATION
Samantha Power
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSONCourtney Wild
PERSON
Harvey Weinstein
PERSON
Santa Fe
LOCATION
Southern District of New York
ORGANIZATION
Alberto Gonzales
PERSONSecond Circuit
ORGANIZATION
White Plains
LOCATION