Epstein Secrets

Jeopardy Clause's Protection Against Duplicative Punishments. 11 III. The Government Should Immediately Produce Accuser-4's Prior Statements as Brady Material. 14 IV. The Court Should Grant Ms. Maxwell's Other Requested Relief. 16 CONCLUSION 17 i EFTA00104412 TABLE OF AUTHORITIES Page

er alleged abuse to the FBI, at a time when the events were most fresh in her mind, is extraordinarily significant. It 5 The government argues that Cambindo Valencia is inapposite because it contends that the charges against the defendant's wife were dismissed because her prosecution violated the defendant's plea

001) 12 North Carolina v. Pearce, 395 U.S. 711 (1969) II, 12, 13 United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) passim United States v. Cambindo Valencia, 609 F.2d 603 (2d Cir. 1979) 13, 14 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 10 United States v. Dionisio, 503 F.3d 78 (2d Cir. 2

d Order a Bill of Particulars as to Counts Five and Six. 22 VII. The Court Should Order the Government to Produce Accuser-4's Prior Statements as Brady Material 24 VIII. Ms. Maxwell Incorporates All of the Arguments Raised in Her Initial Pretrial Motions and Reasserts Them as to the S2 Indictment

passim 820 F.2d 572 (2d Cir. 1987) 22, 23 United States v. Brown, No. 99-1230(L), 2002 WL 34244994 (2d Cir. Apr. 26, 2002) 16 United States v. Cambindo Valencia, 609 F.2d 603 (2d Cir. 1979) 20 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 17 United States v. Garcia-Gonzalez, 714 F.3d 306 (5th C

charges are sufficiently specific. • Maxwell moves to compel the Government to produce the statements of "Minor-Victim 4" in the S2 indictment as Brady material. The Court concludes that the current disclosure schedule gives Maxwell sufficient time to make effective use of any such statements and t

ht not be permissible against a defendant whose charges were dismissed after her husband pleaded guilty. Dkt. No. 293 at 19 (citing United States v. Cambindo Valencia, 609 F.2d 603 (2d Cir. 1979)). However, the Court agrees with the Government that the result in Cambindo Valencia rested on the terms of the husban