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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
has sufficient notice of the Government's theory at trial, she cannot claim that she was unfairly or substantially prejudiced. See United States v. Kaplan, 490 F.3d 119, 129-30 (2d Cir. 2007). Finally, the Court bears in mind that the Defendant brings her motion pursuant to Rule 33, which permits the
o later remained friendly well after her marriage to Glenn Dubin$R4X2°51 Epstein met Maxwell, daughter of disgraced media baron 3.99W1 1 16 2 sos Robert Maxwell, by Epstein had Maxwell come to the United States in 1991 to recover from her grief following the death of her father. 20 Maxwell was implicated b
41241 On 29 October 2021, Andrew's lawyers filed a response, their client "unequw iuffre's false allenations".l122= On 12 January 2022 Judge Kaplan rejected Andrew's attempts to dismiss the case, allowing the sexual abuse lawsuit to proceed. frallii In February, the case was settled out of court
( Accounts differ on when Maxwell first met American financier Jeffrey Epstein. According to Epstein's former business partner, Steven Hoffenberg, Robert Maxwell introduced his daughter to Epstein in the late 198os.144 The Times reported that Maxwell met Epstein in the early 199os at a New York party followi
29 October 2021, Andrew's lawyers filed a response, their client "unequtvocall aeries iuffre's false allegations".U211121) On 12 January 2022 Judge Kaplan rejected Andrew's attempts to dismiss the case, allowing the sexual abuse lawsuit to proceed. U22)021) in February, the case was settled out of cour
e first attracted notice in e early 1990s, it was on account of e woman he was dating: Ghislaine axwell, daughter of the late British edia tycoon Robert Maxwell. In a lengthy article, headlined he Mystery of Ghislaine Max- ill's Secret Love," the British Mail Sunday tabloid laid out specula- •e stories tha
ct info and lead her up a flight of stairs lined with photos of nude women into a bedroom furnished with a massage table. Once the girl was inside, Kaplan would leave and Epstein would enter, wearing only a towel. He would proceed to "remove his towel, lay down naked on the massage table, and direct t
Entities connected to both Robert Maxwell and Kaplan

Jeffrey Epstein
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Prince Andrew
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Bill Clinton
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Marc Rich
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Donald Trump
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Department of Justice
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Virginia Giuffre
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Alan Dershowitz
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New York
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