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e Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA- I met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim
016, AUSA- I met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At
152 VIII. There Is No Basis to Strike Any Portion of the Indictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as '\lultiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. Th
ee Ex. 4 at 1).22 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al
016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwe
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
ee Ex. 4 at 1).22 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al
016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwe
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
1) Doe No. 1. v. United States, 32, 104 33 86 749 F.3d 999 (11th Cir. 2014) 117, 118, 119 Dowling v. United States, 493 U.S. 342 (1990) 52 Edwards v. Mazzuca, No 00 Civ. 2290 (RIS), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 155 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 34 Falter,
ee Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al
limitations set forth in § 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
ee Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim
016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at I).29 At t
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
ue . .. ." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of remembering
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they am m
ssue ...." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, lbJecause minors often are not capable of remembering
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
ssue ...." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, lbJecause minors often are not capable of remembering
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
d States v. Young, 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation 154 EFTA00095246 mark omitted) (quoting Edwards v. Mazzuca, No 00 Civ. 2290 (12.1S), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of rememberin
ree and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. 168 EFTA00095260 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
e . . . ." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (RJS), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of rememberin
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
Entities connected to both Bradley Edwards and The Defendant's Motion

Jeffrey Epstein
PERSONJane Doe
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Alexander Acosta
PERSON
Virginia Giuffre
PERSONDarren Indyke
PERSON
Lesley Groff
PERSON
David Boies
PERSONFBI
ORGANIZATION
Sarah Kellen
PERSON
Julie K. Brown
PERSON