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SSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys
age and drafting history of the NPA does not "affirmatively appear" to bind this District 3 EFTA00103764 as to the SI Indictment counts. However, Annabi, by its own terms, is inapposite to the circumstances of this case, where one federal district has agreed that "the United States" will abandon cer
EN & GRESSER LLP 800 Third Avenue New York, NY 10022 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Attorneys for Ghislaine Ma
-SDNY") because it does not "affirmatively appear" to apply to this District. (Opp. at 2-7). But as we explained in our opening memorandum ("Mem."), Annabi is inapposite to the circumstances of this case. Annabi expressly stated that it was not addressing a situation, like the one here, where one feder
SSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New Attorneys for Ghislaine Maxwell EFTA00
bail proceeding, that are not even foreclosed by the cases the government does cite to you. They cite to you the -- I'm going to skip this one, the Annabi case, A-N-N-A-B-I case, which says, "The plea the office of the U.S. Attorney for the plea is entered unless it affirmatively agreement binds onl
Entities connected to both Denver and Annabi

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Colorado
LOCATION
Michael Cohen
PERSONJeffrey Pagliuca
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
George W. Bush
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Audrey Strauss
PERSON
Michael Jackson
PERSON
Virginia Giuffre
PERSON
Alexander Acosta
PERSONCohen & Gresser LLP
ORGANIZATIONRubin
PERSONEmmy Taylor
PERSONFBI
ORGANIZATION