greement that its own agents negotiated and agreed to with the approval of senior levels of Main Justice. • The government has concocted a federal Mann Act case against Ms. Maxwell by alleging that, on some unspecified occasion during a four-year period between 1994 and 1997, and in an unspecified mann

United States v. Walla, No. 14—CR-213 (MKB), 2014 WL 3734522 (S.D.N.Y. July 25, 2014) 12 Statutes 18 U.S.C. § 2422(a) 7 18 U.S.C. § 2423(a) 7 Mann Act passim Other Authorities Fed. R. Evid. 401 12 Fed. R. Evid. 402 11, 12 Fed. R. Evid. 403 passim Fed. R. Evid. 404(b) passim Fed. R. Evid

s v. Shim, 584 F.3d 394, 396 (2d Cir. 2009); United States v. Evans, 272 F.3d 1069, 1086-87 (8th Cir. 2002) (under general knowledge requirement of Mann Act, jury need not find that defendant knew that the act being committed was unlawful). 24 EFTA00074527 Count Four: Transportation of a Minor to Eng

r girlfriend and we are charging her for her role in recruiting and grooming minor girls to be abused by Epstein. We are charging her with coercion/Mann Act conspiracy and substantive counts, principally, and have a somewhat complicated question about overt acts that is likely easier to explain by phone.

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

with Jeffrey Epstein that would violate N.Y. Penal Law § 130.55. Indictment¶¶ 13, 19. The indictment does not charge Ms. Maxwell with a substantive Mann Act violation as to any individual other than Accuser-1, nor does it allege that Ms. Maxwell personally enticed or caused any person other than Accuser-

United States v. Walla, No. 14—CR-213 (MKB), 2014 WL 3734522 (S.D.N.Y. July 25, 2014) 12 Statutes 18 U.S.C. § 2422(a) 7 18 U.S.C. § 2423(a) 7 Mann Act passim Other Authorities Fed. R. Evid. 401 12 Fed. R. Evid. 402 11, 12 Fed. R. Evid. 403 passim Fed. R. Evid. 404(b) passim Fed. R. Evid

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

ein intended to engage in sexual contact with her. See id. It is the government. not the defense, that apparently does not understand the law. The Mann Act conspiracies charged in the S2 Indictment each require proof that Ms. Maxwell acted with the intent that the alleged victim would "engage in sexual

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

greement that its own agents negotiated and agreed to with the approval of senior levels of Main Justice. • The government has concocted I federal Mann Act case against Ms. Maxwell by alleging that, on some unspecified occasion during I four-year period between 1994 and 1997, and in an unspecified mann

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

ame conduct. Counts Five and Six of the S2 Indictment are therefore barred by the NPA. The Court must dismiss these counts, as well as the expanded Mann Act conspiracies charged in Counts One and Three, which incorporate the same conduct charged in Counts Five and Six for which Ms. Maxwell has immunity.

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.

0330-AJN Document 207 Filed 04/16/21 Page 25 of 34 counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial.