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respect to Maxwell in particular, OPR interviewed Maria Villafatia, the lead prosecutor on the case, and
. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00103012 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) United States v. Farmer, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 4
2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nersesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA00103017 United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011) 201, 202 United States v. Nixon, 418 U.S. 683 (1974) 282 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 W
mental ambiguity," however, "is the exception, not the rule." United States v. Sarwari, 669 F.3d 401, 407 (4th Cir. 2012) (quoting United States v. Farmer, 137 F.3d 1265, 1269 (10th Cir. 1998)). A defendant cannot demonstrate fundamental ambiguity simply by showing that words used in a question are ame
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
at 61-62. However, although the line prosecutor, Maria Villafaiia, subsequently sent the CEOS Chief a d
, 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA00077624 United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011) 201, 202 United States v. Nixon, 418 U.S. 683 (1974) 282 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 W
d following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); SanvaH, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
at 61-62. However, although the line prosecutor, Maria Villafaiia, subsequently sent the CEOS Chief a d
, 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA00039439 United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011) 201, 202 United States v. Nixon, 418 U.S. 683 (1974) 282 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 W
d following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); SanvaH, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
potential co- conspirators of Epstein" evolved from a more narrow provision sought by the defense. The provision expanded as [USAO-SDFL prosecutor Maria] Villafana and defense counsel exchanged drafts of, first, a proposed federal plea agreement and, then, of the NPA, with apparently little analysis
jad, 18 Cr. 224 (AJN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 150 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 154 United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011) 136 United States v. Nixon, 418 U.S. 683 (1974) 190 United States v. Noble, No. 07 Cr. 284 (RJS), 2008 WL 140
following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); Sarivari, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
Entities connected to both Maria Farmer and Nitsche

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Prince Andrew
PERSON
United States
LOCATION
Lesley Groff
PERSON
Scarlett Johansson
PERSON
John F. Kennedy
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONDarren Indyke
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Stephen Hawking
PERSON
George Mitchell
PERSON
Michael Jackson
PERSONFBI
ORGANIZATION