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

7) 274 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 138 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 132 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 256 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 253 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 123

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

017) 274 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 138 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 132 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 256 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 253 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 123

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

nfairly prejudicial where it is not "any more sensational or disturbing than the crimes" with which the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). Here, as already discussed, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are n

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

017) 274 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 138 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 132 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 256 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 253 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 123

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

nfairly prejudicial where it is not "any more sensational or disturbing than the crimes" with which the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). Here, as already discussed, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are n

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

8, 147, 149 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 97 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 93 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 167 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 166 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 87

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

nfairly prejudicial where it is not "any more sensational or disturbing than the crimes" with which the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). Here, as already discussed, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are n

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

nfairly prejudicial where it is not "any more sensational or disturbing than the crimes" with which the defendant has been charged. United States v. Rolan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). Here, as already discussed, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are n

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

7) 274 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 138 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 132 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 256 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 253 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 123