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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 &
which it was made. See, e.g., United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("agreement is limited to the United States Attorney's Office for the District of New Jersey and cannot bind other federal, state, or local authorities"); United States v. Ashraf, 320 F. App'x 26, 28 (2d Cir. 2009) (plea agreement "by its e
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
which it was made. See, e.g., United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("agreement is limited to the United States Attorney's Office for the District of New Jersey and cannot bind other federal, state, or local authorities"); United States v. Ashraf, 320 F. App'x 26, 28 (2d Cir. 2009) (plea agreement "by its e
ed here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "potential co-conspirators" and abandoned any potential federa
s Office for the Southern District of New York ("USAO-SDNY") decided that it was not satisfied with this outcome and is now seeking a "do-over." But Epstein died as a result of the government's own negligence before he could be brought to trial. The government has now targeted Ms. Maxwell as the next be
RESSER LLP 800 Third Avenue New York, NY 10022 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
F. App'x 920, 921 (2d Cir. 2010) (summary order) (plea agreement explicitly stated that "[the] agreement is limited to the United States Attorney's Office for the District of New Jersey and cannot bind other federal, state, or local authorities"); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004) (plea agreement explic
Entities connected to both Jeffrey Epstein and Office for the District of New Jersey

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
ORGANIZATIONJeffrey Pagliuca
PERSON
Alberto Gonzales
PERSONSecond Circuit
ORGANIZATION