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MANDY ELLISON
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This document is a Memorandum of Law in Support of Defendants' Motion to Dismiss, filed in the United States District Court for the Southern District of New York in the derivative litigation against JP Morgan Chase & Co. It outlines arguments regarding pleading standards, demand futility, and failure to state claims against the defendants, including specific points related to JPMorgan's termination of Epstein as a client and the oversight of internal controls by the board of directors. The document includes a table of authorities citing numerous legal cases.
This document is an email header dated August 11, 2019 (01:28 UTC, which is late evening August 10 EST), the same day Jeffrey Epstein died at MCC NYC. The subject line 'Inmate Ellison Memo' and the attachment 'memoblankMCCNYC.docx' suggest internal correspondence at the Metropolitan Correctional Center regarding an inmate memo, though the name 'Ellison' is notable given the context of Epstein's death that day.
This document is page 17 of a court filing (Document 22) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 13, 2020. The text argues against granting bail, citing an 'extraordinary risk of flight' and rejecting the defendant's claim that detention at the MDC prevents adequate preparation for defense. The filing cites numerous precedents (Tolentino, Adamu, Brito, etc.) where bail was denied despite access-to-counsel restrictions, distinguishing the current case from *United States v. Stephens*.
This document is page 22 of a contact list, likely an address book, containing entries for individuals whose last names begin with 'E'. The list includes individuals and couples, but their personal contact information has been redacted, as noted at the top of the page. The document is marked with the identifier DOJ-OGR-00022307.
This document is a page of endnotes (page 310) from a book discussing Edward Snowden, listing sources and citations for Chapter 4 ("Thief") and Chapter 5 ("Crossing the Rubicon"). It references interviews, articles, and transcripts involving Snowden, government officials, and journalists.
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