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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 &
analysis. 19 a. There is an "affirmative appearance" that the co-conspirator immunity provision was intended to apply outside the SDFL 20 b. The Second Circuit's subsequent application of Annabi supports Ms. Maxwell's position 22 c. To the extent that Annabi conflicts with Eleventh Circuit law, Eleventh C
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
analysis. 19 1. There is an "affirmative appearance" that the co-conspirator immunity provision was intended to apply outside the SDFL 20 b. The Second Circuit's subsequent application of Annabi supports Ms. Maxwell's position 22 c. To the extent that Annabi conflicts with Eleventh Circuit law, Eleventh C
From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Insider Trading
below. Alex Gelinas, Daniel G. Viola, Danielle Epstein-Day, Douglas Hirsch, Jeffrey Goldberg, Jennife
From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Insider Tra
ra and Adondakis, who in turn gave the information to Newman and Chiasson, making Newman and Chiasson four levels removed from the inside tippers. The Second Circuit's Explanation of Tipper-Tippee Liability The Second Circuit noted that the original tippers-Ray and Choi-had not been charged administratively, civil
Entities connected to both Jeffrey Epstein and The Second Circuit's

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