Epstein Secrets

eafter did perform a crime of violence to further the unlawful activity, and did • aid and abet the same, and death resulted, to wit, after Urbano Santiago accompanied Martin Luna to the Likquid Lounge, where Luna had been lured by TARTAGLIONE and others, Urbano Santiago was held captive, transported t

IONE, the defendant, intentionally and knowingly killpd, and counseled, commanded, induced, procured, and caused the intentional killing of Urbano.Santiago, in and around the vicinity of 419 Old Mountain Road in Otisville, New York, and did aid and abet the same. (Title 21, United States Code, Section

pstein was incarcerated at the MCC between his arrest on July 6, 2019, and his suicide on August 10, 2019. Epstein was detained pending trial in the Southern District of New York on sex trafficking charges. THE MCC AND INSTITUTIONAL COUNTS 6. The MCC, which houses approximately 750 inmates at any given time, as

IONE, the defendant, intentionally and knowingly killpd, and counseled, commanded, induced, procured, and caused the intentional killing of Urbano.Santiago, in and around the vicinity of 419 Old Mountain Road in Otisville, New York, and did aid and abet the same. (Title 21, United States Code, Section

eafter did perform a crime of violence to further the unlawful activity, and did • aid and abet the same, and death resulted, to wit, after Urbano Santiago accompanied Martin Luna to the Likquid Lounge, where Luna had been lured by TARTAGLIONE and others, Urbano Santiago was held captive, transported t

TARTAGLIONE, Defendant. X COUNT ONE The Grand Jury charges: 1. From at least in or about 2015, up to and including in or about April 2016, in the Southern District of New York and elsewhere, NICHOLAS TARTAGLIONE, the defendant, and others known and unknown, intentionally and knowingly did combine, conspire, c

eafter did perform a crime of violence to further the unlawful activity, and did • aid and abet the same, and death resulted, to wit, after Urbano Santiago accompanied Martin Luna to the Likquid Lounge, where Luna had been lured by TARTAGLIONE and others, Urbano Santiago was held captive, transported t

IONE, the defendant, intentionally and knowingly killpd, and counseled, commanded, induced, procured, and caused the intentional killing of Urbano.Santiago, in and around the vicinity of 419 Old Mountain Road in Otisville, New York, and did aid and abet the same. (Title 21, United States Code, Section

ONE I, Russell Capone, hereby declare as follows: I. I am Counsel to the Acting United States Attorney in the United States Attorney's Office for the Southern District of New York ("USAO-SDNY"). I have served in this capacity since June 2020. Prior to my current role, I served as Deputy Chief and then Chief of the

287 (2d Cir. 2018) 177, 178, 188 United States v. Samson or, No. 07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 269 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Saftar, 272 F. Supp.

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

d 287 (2d Cir. 2018) 177, 178, 188 United States v. Samsonov, No. 07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 269 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Sattar, 272 F. Supp.

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

d 287 (2d Cir. 2018) 177, 178, 188 United States v. Samsonov, No. 07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 269 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Sattar, 272 F. Supp.

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

898 F.3d 287 (2d Cir. 2018) 120, 125 United States v. Samsonov, 07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 177 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 52 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 120, 121 United States v. Sattar, 272 F. Supp.

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

of implication Unit States' Dudley, 62 F.3d 1275, 1278 (10th Cir. 1995); Oiled States Patriarca, 948 F.2d 789, 793 (1st Cir. 1991); United States Santiago, 826 F.2d 499 (7th Cir. 1987). "[There is no conflict between Rule 46(f) and the Bail Reform Act; the Rule and the Act are complementary and form a

gned to the case for immediate revocation of the Magistrate Judge's Order. THE CHARGES IN THE INDICTMENT On April , 2008, a Grand Jury sitting in the Southern District of Florida returned a twenty-nine-count indictment charging defendant Jeffrey Epstein' with one count of conspiracy to use a means of interstate co

287 (2d Cir. 2018) 177, 178, 188 United States v. Samsonov, No. 07 Cr. 1198 (CM), 2009 WL 176721 (S.D.N.Y. Jan. 23, 2009) 269 United States v. Santiago, 987 F. Supp. 2d 465 (S.D.N.Y. 2013) 75 United States v. Sarwari, 669 F.3d 401 (4th Cir. 2012) 179, 180 United States v. Sattar, 272 F. Supp.

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

ct the Intervenors from "annoyance, embarrassment, oppression, or undue burden or expense." See Looney, 2014 U.S. Dist. LENS 48349, at *5; Irizarry- Santiago'. Essilor Industries, 293 F.R.D. 100, 104 (D. P.R. 2013). The Intervenors include not only the third-party client whose non-prosecution agreement is

een Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Leflcowitz), and the U.S. Attorney's office for the Southern District of Florida.,] reptesentect-pciffier-ily-by Assistent-U7SrAttemey-Ar MaFie--WHefefier-ae-plea-diseussiens-genecally-begen-from-Ihe premise-that-Bpst