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EFTA00074500
Dataset 9
90p
18,563w
…a separate verdict of guilty or not guilty for each. Whether you find the defendant guilty or not guilty as to one offense should not affect your verdict as to any other offense charged, unless you are instructed otherwise. With that summary of the Indictment as background, I will now give you detailed instructions that relate to the crimes charged in
Counts One
through Six. Adapted from the charge of the Hon. Alison J. Nathan in United States v. Pizarro…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074500.pdf
EFTA00024023
Dataset 8
2021-03-15
2p
619w
…memoranda with accompanying exhibits: I. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement 2. Reply Memorandum in Support of Motion to Dismiss
Counts One
through Four of the Superseding Indictment as Time-Barred 3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 4. Reply Memorandum in Support of Motion…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00024023.pdf
EFTA00028925
Dataset 8
2021-03-15
2p
629w
…with accompanying exhibits: I. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement 2. Reply Memorandum in Support of Motion to Dismiss
Counts One
through Four of the Superseding Indictment as Time-Barred 3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six 4. Reply Memorandum in Support of…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028925.pdf
EFTA00097329
Dataset 9
2021-03-15
2p
624w
…memoranda with accompanying exhibits: 1. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement 2. Reply Memorandum in Support of Motion to Dismiss
Counts One
through Four of the Superseding Indictment as Time-Barred 3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 4. Reply Memorandum in Support of Motion…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097329.pdf
EFTA00091875
Dataset 9
2008-01-16
19p
4,850w
…Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00091875 TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES ii INTRODUCTION 1 OVERVIEW OF THE ALLEGATIONS 2 A.
Counts One
through Four (the "Mann Act Counts") 2 B. Counts Five and Six (the "Perjury Counts") 2 APPLICABLE LAW 3 A. Joinder of Offenses 3 B. Severance of Offenses 5 ANALYSIS 6 A. …
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091875.pdf
EFTA00156400
Dataset 9
2022-04-29
45p
15,329w
…therefore entry ofjudgment on all three counts would violate the Fifth Amendment's Double Jeopardy Clause. Second, she requests under Rule 29 of the Federal Rules of Criminal Procedure that the Court acquit her of all counts because there is insufficient evidence for any rational juror to find her guilty beyond a reasonable doubt. Third, the Defendant moves to vacate
Counts One
, Three, and Four under Rule 33 because, she claims, the convictions were based on a constructive amendment of…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00156400.pdf
EFTA00793686
Dataset 9
2018-10-11
6p
2,084w
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: PART 81 X The People of the State of New York • - against - : Decision and Order Harvey Weinstein, Ind. No. 2335/18 Defendant. X James M. Burke, J.: The defendant is charged by indictment with five) felony sex offenses, specifically,
Counts One
and Three charge Predatory Sexual Assault, Penal Law §130.95(2), Count Two charges Criminal Sexual Act in the First Degree, PL §130.50(1), Count Four…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793686.pdf
EFTA00095654
Dataset 9
2021-01-25
2p
465w
…we will be filing the following pretrial motions with accompanying exhibits: I. Motion to Dismiss the Superseding Indictment for Breach of the Non-Prosecution Agreement 2. Motion to Dismiss
Counts One
through Four of the Superseding Indictment as Time- Barred 3. Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 4. Motion to Dismiss Counts Five and Six of the Superseding Indictment Because the Alleged…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095654.pdf
EFTA00104411
Dataset 9
23p
6,234w
…Denver, Colorado 80203 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Attorneysfor Ghislaine Maxwell EFTA00104411 TABLE OF CONTENTS Page ARGUMENT 3 I. The Court Should Not Apply the Annabi Rule and Instead Find that the NPA Bars Ms. Maxwell's Prosecution on
Counts One
, Three, Five, and Six 3 II. Prosecuting Ms. Maxwell on Counts Five and Six Would Violate the Double Jeopardy Clause's Protection Against Duplicative Punishments…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104411.pdf
EFTA00103709
Dataset 9
2018-08-09
25p
6,523w
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) v. GHISLAINE MAXWELL, Defendant. x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS
COUNTS ONE
THROUGH FOUR OF THE SUPERSEDING INDICTMENT AS TIME-BARRED Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103709.pdf
EFTA02731226
Dataset 12
2020-04-10
28p
8,682w
…and willfully joined: and (3) at least one overt act in furtherance of the conspiracy. The elements of these crimes are discussed in detail in our April 10, 2020 prosecution memorandum. We would propose expanding the conspiracy al sad charged in
Counts One
and Three to continue through 2004, which is the last year when went to Epstein's home as a minor. testimony would establish that Maxwell agreed wit to commit each element o t 18 U.S.C. …
https://www.justice.gov/epstein/files/DataSet%2012/EFTA02731226.pdf
EFTA00029138
Dataset 8
2021-04-29
2p
474w
Subject:
RE: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer
From:
'
To:
Laura Mennin. er •
… Or if you would prefer to confer by email, would you please let us know your position? Additionally, we intend to submit a letter to Judge Nathan requesting that time under the Speedy Trial Act be excluded through the date the Court intends to set for trial of
Counts One
through Six of the S2 Indictment. Although Judge Nathan previously excluded time through July 12, 2021, she has not reissued such an order since the return of the 52 Indictment…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029138.pdf
EFTA00038962
Dataset 8
2022-04-29
3p
467w
Subject:
[EXTERNAL EMAIL] - FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell
…Finally, the Court grants the Defendant's motion as to multiplicity. The Government concedes that Count One is multiplicitous with Count Three, and the Court further concludes that Count Five is multiplicitous with Count Three. Count Five, like
Counts One
and Three, charged the Defendant's participation in the same decade-long unlawful agreement with the Defendant's continuous coconspirator, Jeffrey Epstein, to groom and sexually abuse underage girls. Accordingly, the Court will enter judgment of conviction on Counts Three…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00038962.pdf
EFTA00022486
Dataset 8
2021-04-29
2p
467w
Subject:
FW: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer
From:
(USANYS)" <
To:
' )" C >, 11
… Or if you EFTA00022486 would prefer to confer by email, would you please let us know your position? Additionally, we intend to submit a letter to Judge Nathan requesting that time under the Speedy Trial Act be excluded through the date the Court intends to set for trial of
Counts One
through Six of the 52 Indictment. Although Judge Nathan previously excluded time through July 12, 2021, she has not reissued such an order since the return of the 52…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00022486.pdf
EFTA00023329
Dataset 8
2020-10-14
6p
2,086w
…They Refute the Government's Theory of the Charged Crimes The government states that, as part of its "broader investigation into Epstein's sexual abuse of minors," it interviewed "dozens" of alleged victims of Epstein's sexual abuse and obtained sensitive documents and photographs from certain alleged victims who claim they were assaulted after 1997 — i.e., after the end of the time period charged in
Counts One
through Four of the superseding indictment (the "Indictment"). (Dkt. 60 at 2)…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023329.pdf
EFTA00022504
Dataset 8
2021-04-29
3p
913w
Subject:
RE: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer
From:
'
To:
'eMinia1YS)" <=l >, '1
…if you would prefer to confer by email, would you please let us know your position? Additionally, we intend to submit a letter to Judge Nathan requesting that time under the Speedy Trial Act be excluded through the date the Court intends to set for trial of
Counts One
through Six of the S2 Indictment. Although Judge Nathan previously excluded time through July 12, 2021, she has not reissued such an order since the return of the S2 Indictment, and…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00022504.pdf
EFTA00010414
Dataset 8
2021-07-02
3p
837w
…we argued in our supplemental pretrial motions currently pending before the Court (Dkt. 293), the government has failed to abide by its promise not to prosecute Ms. Maxwell for the offenses for which she was immunized by the Epstein Non- Prosecution Agreement ("NPA"). We submit that this decision provides support for Ms. Maxwell's supplemental motion to dismiss
Counts One
, Three, Five, and Six of the S2 Indictment for violation of the NPA. In Cosby, Andrea Constand alleged that Mr…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00010414.pdf
EFTA00066546
Dataset 9
2020-10-23
7p
3,628w
…Its October 7, 2020 letter is simply the harbinger of future delay, obfuscation, and impairment of Ms. Maxwell's ability to defend herself. Background Regarding the Lack of Substantive Disclosure by the Government Regarding
Counts One
Through Fours The "speaking" indictment in this case is remarkable because it fails to identify an accuser, a specific date that Ms. Maxwell is alleged to have committed a crime, or when anything in furtherance of any alleged conspiracy occurred. The only dates contained…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00066546.pdf
EFTA00082136
Dataset 9
2021-01-28
2p
546w
…is an integral part of our criminal justice system."). • The proposed redactions to the defendant's motion to dismiss
Counts One
through Four of the Superseding Indictment as time-barred (Motion 2) and her motion to strike surplusage from the Superseding Indictment (Motion 6) protect the privacy interest of a victim-witness. • The proposed redactions to the motion to dismiss Counts Five and Six (Motion 4) refer to documents designated by the Government as "Confidential" within the meaning of the…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00082136.pdf
EFTA00207722
Dataset 9
2010-03-29
29p
9,495w
…vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEMENT & STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT [dated 2/23/20101 Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to dismiss
Counts One
through Six of Plaintiff JANE DOE 103's Complaint for failure to state a cause of action, as specified herein. Rule 12(b)(6), Fed.R.Civ.P. (2009); Local Gen. Rule 7.1 (S.D. Fla…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207722.pdf
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