Epstein Secrets

194 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2005) 257 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 207,214,217 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 170 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020), tert denied, No. 20-5064, -- S.O. -- , 2021 WL 78

f articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, "Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark," Miami Herald (Nov. 28, 2018).3i AUSA-1 was not involved in

tates v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 155 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en bane) 54 United States v. Dornau, 356 F. Supp. 1091 (S.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SJF) (

Thus, the defendant's claim that she no longer has access to certain evidence is not a proper basis to dismiss the Indictment. See United States v. Dornau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973) ("A bare allegation that records have been lost or destroyed, which might relate IS The Government notes t

d States v. Brand, 556 F.2d 1312 (5th Cir. 1977) 52 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 139, 143, 145 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 115 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020) 26, 29 United States v. Brown, No. 07-0296, 200

articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, Even from Jail, Sex Abuser Manipulated The System. His Victims Were Kept in The Dark, Miami Herald, Nov. 28, 2018.32 AUSA-1 was not involved in the

6 United States v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 106 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) 39 United States v. Dornau, 356 F. Supp. 1091 (S.D.N.Y. 1973) 50 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 156 United States v. Dumitru, 18 Cr. 243 (LAK), 201

Thus, the defendant's claim that she no longer has access to certain evidence is not a proper basis to dismiss the Indictment. See United States v. Dornau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973) ("A bare allegation that records have been lost or destroyed, which might relate to the instant Is The Gov

94 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2005) 257 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 207, 214, 217 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 170 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020), cert denied, No. 20-5064, S.Ct. , 2021 WL 78235

f articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, "Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark," Miami Herald (Nov. 28, 2018).31 AUSA-1 was not involved in

States v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 155 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en banc) 54 United States v. Dornau, 356 F. Supp. 1091 (S.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SW) (A

94 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2005) 257 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 207, 214, 217 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 170 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020), cert denied, No. 20-5064, S.Ct. , 2021 WL 78235

f articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, "Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark," Miami Herald (Nov. 28, 2018).31 AUSA-1 was not involved in

States v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 155 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en banc) 54 United States v. Dornau, 356 F. Supp. 1091 (S.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SW) (A

94 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2005) 257 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 207, 214, 217 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 170 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020), cent denied, No. 20-5064, S.Ct. , 2021 WL 78235

f articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, "Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark," Miami Herald (Nov. 28, 2018).3' AUSA-1 was not involved in

tates v. DiGregorio, 795 F. Supp. 630 (S.D.N.Y. 1992) 155 United States v. Dodge, 597 F.3d 1347 (11th Cir. 2010) (en banc) 54 United States v. Dornau, 356 F. Supp. 1091 (S.D.N.Y. 1973) 73 United States v. Dorvee, 616 F.3d 174 (2d Cir. 2010) 236 United States v. Drago, No. 18 Cr. 0394 (SJF) (

urts and prosecutors," ensuring that a court does not "exceed 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 impli

de only a "bare allegation that [certain] records have been lost or destroyed," but without explaining when or why they were lost. United States v. Dornau, 356 F. Supp. 1091, 1094 (S.D.N.Y. 1973). Further, the Defendant does not explain whether any attempt was made to acquire these records either direc