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gument as to why Count One was constructively amended is the same as her argument as to Count Three, and the Court's analysis would be the same. See Maxwell Br. at 16. 24 EFTA00156423 Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 25 of 45 1. The Court's instructions, the evidence at trial, and
jury convicted the Defendant on all three conspiracy counts, the Defendant now requests that the Court impose judgment on only one of these counts. Maxwell Br. at 19, Dkt. No. 600. The Government concedes that Counts One and Three are multiplicitous and agrees that the Court should not impose judgment on
ed its legislative authorization by imposing multiple punishments for the same offense." Brown v. Ohio, 432 U.S. 161, 165 (1977); see also Morris v. Reynolds, 264 F.3d 38, 48 (2d Cir. 2001). An indictment is multiplicitous, and therefore implicates double jeopardy, "when it charges a single offense as an
nch on campus one day. That was in February 2001 and the stranger, whom she later discovered was Ghislaine Maxwell — daughter of the late, disgraced Robert Maxwell — had an unusual proposition: in return for $20 an hour, she was to answer the phones and serve occasional drinks at Epstein's home. She recalls: "
lis, Melanie DOVE -TD) Quintana, Tania CC E) Quires. Cynthia NVEST) Reamsnyder, Adam Civil Rights) Rex, Marti DUI) Reynolds, Easton Admin) Reynolds, Nadene CAC) Rhoden, Sharon Fel) Richstone, Jill CC L) Rivera, Marlene tel R) Roberts, Ellen Bello Glade) Robinson, Dana Juv M) Rodriguez,
owell, Lynn (INTAKE) Powlis, Melanie DOVE -TD) Quintana, Tania CC E) Quires. Cynthia NVEST) Reamsnyder, Adam Civil Rights) Rex, Marti DUI) Reynolds, Easton Admin) Reynolds, Nadene CAC) Rhoden, Sharon Fel) Richstone, Jill CC L) Rivera, Marlene tel R) Roberts, Ellen Bello Glade) Robinson
HOUSE_OVERSIGHT_014665 --- PAGE BREAK --- Case Document 5 6/14/2016 Organiser: Ghislaine Maxwell looks on as Andrew put his arm around Virginia. Robert Maxwell's daughter k as E i invited her to ersonal masseuse soon after her 15th birthday We kissed on the cheek and Ghislaine placed me on his other knee.’ Jo
Page: HOUSE_OVERSIGHT_014666 →its guy would do anything wrong. | was planning to vote for him when | turned 18. | thought he was way and why she fell in awesome.’ love with Ryan Reynolds Virginia said that yet another American liberal icon, President Obama's Middie East peace envoy Senator George Mitchell, frequently visited Epstein
Page: HOUSE_OVERSIGHT_014671 →Entities connected to both Robert Maxwell and Reynolds

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Marc Rich
PERSON
Donald Trump
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
New York
LOCATION
Virginia Giuffre
PERSON
Vicky Ward
PERSON
Bradley Edwards
PERSON
Department of Justice
ORGANIZATION
Mort Zuckerman
PERSONJane Doe
PERSON
United States
LOCATION
Stephen Hawking
PERSON
Joe Biden
PERSON
George W. Bush
PERSONthe Southern District
LOCATION