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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
986)); see also United States v. Mallah, 503 F.2d 971, 986 (2d Cir. 1974) (applying this burden-shifting approach post-conviction); United States v. Hernandez, No. 09-CR-625 (HB), 2009 WL 3169226, at *9 (S.D.N.Y. Oct. 1, 2009). 6 EFTA00156405 Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 7 of
reported to have monitored the property for four hours prior to the 8:20am raid to ensure the daughter of late and controversial media mogul and MP Robert Maxwell was unable to flee. Armed law officers allegedly broke down the building's front door to find the former socialite 'strangely' passive and subdued a
s!" In Response To Coronavirus, States And Cities Cancel, Limit Fourth Of July Celebrations. EFTA00148662 According to the Washington Post (7/3, Hernandez, Guarino, 14.2M), "Cities and communities of all sizes, from Miami to Los Angeles, are dispensing with the elaborate Independence Day festivities t
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: "
TD) Harvey, Lynn DOVE-Fell Head, Amanda CC L) Heald, Patricia CC L) Hearsurn, Debra Fel W) Herbits, Linda JlmmyRyce) Herman, Ron So Cnty) Hernandez, Janine CC E) Herat, Dana Collier CC 8) Higgins, Stephanie (Fel W) (IFCFNv etf ill s) 71 (No Cnty) (Felony) Kiviroglu, Karmen (INVEST) Kler
Entities connected to both Robert Maxwell and Hernandez

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Donald Trump
PERSON
Marc Rich
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
Alan Dershowitz
PERSON
New York
LOCATION
Les Wexner
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Vicky Ward
PERSON
Joe Biden
PERSON
Stephen Hawking
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Scarlett Johansson
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George W. Bush
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