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e evidence of innocent travel was necessary to rebut the government's allegation that Williams had been involved in other cocaine importations from Jamaica. Although the government did argue that Williams had been involved in other importations, it did not allege that Williams had engaged in drug activi
he defendant invites the Court to engage in a balancing test that weighs the prejudice to the defendant against the Government's reasons for delay. (Del Mot. 7 at 5,6 n.4). This Court should reject the defendant's invitation. The defendant cites United States v. Brand, 556 F.2d 1312, 1317 n.7 (5th Cir.
e evidence of innocent travel was necessary to rebut the government's allegation that Williams had been involved in other cocaine importations from Jamaica. Although the government did argue that Williams had been involved in other importations, it did not allege that Williams had engaged in drug activi
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
e evidence of innocent travel was necessary to rebut the government's allegation that Williams had been involved in other cocaine importations from Jamaica. Although the government did argue that Williams had been involved in other importations, it did not allege that Williams had engaged in drug activi
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
Entities connected to both Jamaica and Del Mot

Jeffrey Epstein
PERSON
John F. Kennedy
PERSON
United States
LOCATION
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Lesley Groff
PERSON
Department of Justice
ORGANIZATIONDarren Indyke
PERSON
Julie K. Brown
PERSON
Michael Jackson
PERSONEmmy Taylor
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSONFBI
ORGANIZATION
Michigan
LOCATION
Colorado
LOCATION
North Carolina
LOCATIONthe Southern District
LOCATION