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hours in a 30-day period; and went on an unauthorized visit to a restaurant in Chinatown with his private guards in tow"); see also United States v. Tajideen, 17 Cr. 046, 2018 WL 1342475, at *5-6 (D.D.C. Mar. 15, 2018) (finding Zarrab "particularly instructive" and further noting: "While the Court has no
Page: EFTA00015540 →iction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal prosecutor agrees that 'the Government' will dism
Page: EFTA00015544 →ngs in this case or protect the safety of the community, and that any application for bail should be denied. Very truly yours, GEOF REY S. BERMAN United tates Attorney By: Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324 Cc: Martin Weinberg, Esq., and Re
Page: EFTA00015556 →'s application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp.2d 32, 41 (D.D.C. 2005) (sa
Page: EFTA00028792 →hours in a 30-day period; and went on an unauthorized visit to a restaurant in Chinatown with his private guards in tow"); see also United States v. Tajideen, 17 Cr. 046, 2018 WL 1342475, at *5-6 (D.D.C. Mar. 15, 2018) (finding Zarrab "particularly instructive" and further noting: "While the Court has no
Page: EFTA00028793 →iction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal prosecutor agrees that 'the Government' will dism
Page: EFTA00028797 →v. Valerio, 9 F. Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, EFTA00030252 --- PAGE BREAK --- Honorable Richard M
Page: EFTA00030252 →hours in a 30-day period; and went on an unauthorized visit to a restaurant in Chinatown with his private guards in tow"); see also United States v. Tajideen, 17 Cr. 046, 2018 WL 1342475, at *5-6 (D.D.C. Mar. 15, 2018) (Finding Zarrab "particularly instructive" and further noting: "While the Court has no
Page: EFTA00030254 →Entities connected to both United States and Tajideen

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
Julie K. Brown
PERSONMartin Weinberg
PERSON
Michael Cohen
PERSON
Michael Jackson
PERSON
U.S. Virgin Islands
LOCATION
George Mitchell
PERSONEmmy Taylor
PERSON
Geoffrey S. Berman
PERSON
Harry Reid
PERSON
New York State
LOCATIONSecond Circuit
ORGANIZATION
Anderson
PERSON
Reid Weingarten
PERSONMorrison
PERSON
Ashcroft
PERSON