Epstein Secrets

ing, 560 F.2d 122 (2d Cir. 1977) 64 United States v. Kozel, No. 19 Cr. 460 (KMW), 2020 WL 4751498 (S.D.N.Y. Aug. 17, 2020) 236 United States v. Kross, 14 F.3d 751 (2d Cir. 1994) 183, 221, 222 United States v. Lanam, 369 F.3d 153 (2d Cir. 2004) 254 United States v. Lahey, 967 F. Supp. 2d 698

agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 20-21. Aside from the reference to "United States" which, as noted above, is insuffic

274 United States v. Bellomo, 263 F. Supp. 2d 561 (E.D.N.Y. 2003) 268 United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d

uthful answer might reasonably be calculated to lead to the discovery of evidence admissible at the trial of the underlying suit." United States v. Kross, 14 F.3d 751, 754 (2d Cir. 1994)); see United States v. Birrell, 470 F.2d 113, 115 n.1 (2d Cir. 1972) (explaining, in the context of a motion to pro

United States v. An Antique Platter of Gold, 184 F.3d 131, 135-36 (2d Cir. 1999) (distinguishing the "natural tendency test" from a but-for test); Kross, 14 F.3d at 754 (rejecting, in a civil forfeiture case, the argument that the defendant's true testimony would not itself have justified a forfeitur

that may, on their own, be untimely can nevertheless serve as direct evidence of the existence of a charged conspiracy. See, e.g., United States v. Benussi, 216F. Supp. 2d 299, 301-07, 309 (S.D.N.Y. 2002) (admitting evidence of otherwise untimely acts during conspiracy trial); cf. United States v. Marc

ing, 560 F.2d 122 (2d Cir. 1977) 64 United States v. Kozel, No. 19 Cr. 460 (KMW), 2020 WL 4751498 (S.D.N.Y. Aug. 17, 2020) 236 United States v. Kross, 14 F.3d 751 (2d Cir. 1994) 183, 221, 222 United States v. LaFlam, 369 F.3d 153 (2d Cir. 2004) 254 United States v. Lahey, 967 F. Supp. 2d 698

agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insuffic

274 United States v. Bellomo, 263 F. Supp. 2d 561 (E.D.N.Y. 2003) 268 United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d

uthful answer might reasonably be calculated to lead to the discovery of evidence admissible at the trial of the underlying suit." United States v. Kross, 14 F.3d 751, 754 (2d Cir. 1994)); see United States v. Birrell, 470 F.2d 113, 115 n.1 (2d Cir. 1972) (explaining, in the context of a motion to pro

United States v. An Antique Platter of Gold, 184 F.3d 131, 135-36 (2d Cir. 1999) (distinguishing the "natural tendency test" from a but-for test); Kross, 14 F.3d at 754 (rejecting, in a civil forfeiture case, the argument that the defendant's true testimony would not itself have justified a forfeitur

that may, on their own, be untimely can nevertheless serve as direct evidence of the existence of a charged conspiracy. See, e.g., United States v. Benussi, 216 F. Supp. 2d 299, 301-07, 309 (S.D.N.Y. 2002) (admitting evidence of otherwise untimely acts during conspiracy trial); cf. United States v. Mar

ing, 560 F.2d 122 (2d Cir. 1977) 64 United States v. Kozel, No. 19 Cr. 460 (KMW), 2020 WL 4751498 (S.D.N.Y. Aug. 17, 2020) 236 United States v. Kross, 14 F.3d 751 (2d Cir. 1994) 183, 221, 222 United States v. LaFlam, 369 F.3d 153 (2d Cir. 2004) 254 United States v. Lahey, 967 F. Supp. 2d 698

agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insuffic

274 United States v. Bellomo, 263 F. Supp. 2d 561 (E.D.N.Y. 2003) 268 United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d

uthful answer might reasonably be calculated to lead to the discovery of evidence admissible at the trial of the underlying suit." United States v. Kross, 14 F.3d 751, 754 (2d Cir. 1994)); see United States v. Birrell, 470 F.2d 113, 115 n.1 (2d Cir. 1972) (explaining, in the context of a motion to pro

United States v. An Antique Platter of Gold, 184 F.3d 131, 135-36 (2d Cir. 1999) (distinguishing the "natural tendency test" from a but-for test); Kross, 14 F.3d at 754 (rejecting, in a civil forfeiture case, the argument that the defendant's true testimony would not itself have justified a forfeitur

that may, on their own, be untimely can nevertheless serve as direct evidence of the existence of a charged conspiracy. See, e.g., United States v. Benussi, 216 F. Supp. 2d 299, 301-07, 309 (S.D.N.Y. 2002) (admitting evidence of otherwise untimely acts during conspiracy trial); cf. United States v. Mar

v. King, 560 F.2d 122 (2d Cir. 1977) 44 United States v. Kozel, 19 Cr. 460 (KMW), 2020 WL 4751498 (S.D.N.Y. Aug. 17, 2020) 155 United States v. Kross, 14 F.3d 751 (2d Cir. 1994) 122, 148 United States v. LaFlam, 369 F.3d 153 (2d Cir. 2004) 166 United States v. Lahey, 967 F. Supp. 2d 698 (S.D

agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insuffic

182 United States v. Bellomo, 263 F. Supp. 2d 561 (E.D.N.Y. 2003) 176 United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 31 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 163, 164 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 176 United States v. Biaggi, 909 F.2d

uthful answer might reasonably be calculated to lead to the discovery of evidence admissible at the trial of the underlying suit." United States v. Kross, 14 F.3d 751, 754 (2d Cir. 1994)); see United States v. Birrell, 470 F.2d 113, 115 n.1 (2d Cir. 1972) (explaining, in the context of a motion to pro

United States v. An Antique Platter of Gold, 184 F.3d 131, 135-36 (2d Cir. 1999) (distinguishing the "natural tendency test" from a but-for test); Kross, 14 F.3d at 754 (rejecting, in a civil forfeiture case, the argument that the defendant's true testimony would not itself have justified a forfeitur

that may, on their own, be untimely can nevertheless serve as direct evidence of the existence of a charged conspiracy. See, e.g., United States v. Benussi, 216 F. Supp. 2d 299, 301-07, 309 (S.D.N.Y. 2002) (admitting evidence of otherwise untimely acts during conspiracy trial); cl United States v. Marc

uthful answer might reasonably be calculated to lead to the discovery of evidence admissible at the trial of the underlying suit." United States v. Kross, 14 F.3d 751, 754 (2d Cir. 1994)); see United States v. Bitrell, 470 F.2d 113, 115 n.1 (2d Cir. 1972) (explaining, in the context of a motion to pro

United States v. An Antique Platter of Gold, 184 F.3d 131, 135-36 (2d Cir. 1999) (distinguishing the "natural tendency test" from a but-for test); Kross, 14 F.3d at 754 (rejecting, in a civil forfeiture case, the argument that the defendant's true testimony would not itself have justified a forfeitur

that may, on their own, be untimely can nevertheless serve as direct evidence of the existence of a charged conspiracy. See, e.g., United States v. Benussi, 216 F. Supp. 2d 299, 301-07, 309 (S.D.N.Y. 2002) (admitting evidence of otherwise untimely acts during conspiracy trial); cf. United States v. Mar

ing, 560 F.2d 122 (2d Cir. 1977) 64 United States v. Kozel, No. 19 Cr. 460 (KMW), 2020 WL 4751498 (S.D.N.Y. Aug. 17, 2020) 236 United States v. Kross, 14 F.3d 751 (2d Cir. 1994) 183, 221, 222 United States v. LaFlam, 369 F.3d 153 (2d Cir. 2004) 254 United States v. Lahey, 967 F. Supp. 2d 69

274 United States v. Bellomo, 263 F. Supp. 2d 561 (E.D.N.Y. 2003) 268 United States v. Ben Zvi, 242 F.3d 89 (2d Cir. 2001) 41 United States v. Benussi, 216 F. Supp. 2d 299 (S.D.N.Y. 2002) 248, 250 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d