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

States v. Mantilla), 606 F. Supp. 2d 370 (S.D.N.Y. 2009) 284 United States v. Trippe, 171 F. Stipp. 2d 230 (S.D.N.Y. 2001) 267 United States v. Triumph Capital Group, Inc., 237 F. App'x 625 (2d Cir. 2007) 184, 187 United States v. Turoff, 853 F.2d 1037 (2d Cir. 1988) 204 United States v. Ulbricht, No. 14 Cr. 68

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 are properly put to the jury and not a basis to dismiss the counts pretrial and without the benefit of a complete record. See United States v. Triumph Capital Group, Inc., 237 F. App'x 625, 627-28 (2d Cir. 2007) ("Generally, the meaning and truthfulness of a defendant's statement is a question of fact for the 122 EF

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

States v. Tranquillo, 606 F. Supp. 2d 370 (S.D.N.Y. 2009) 284 United States v. Trippe, 171 F. Supp. 2d 230 (S.D.N.Y. 2001) 267 United States v. Triumph Capital Group, Inc., 237 F. App'x 625 (2d Cir. 2007) 184, 187 United States v. Turoff, 853 F.2d 1037 (2d Cir. 1988) 204 United States v. Ulbricht, No. 14 Cr. 68 (

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 are properly put to the jury and not a basis to dismiss the counts pretrial and without the benefit of a complete record. See United States v. Triumph Capital Group, Inc., 237 F. App'x 625, 627-28 (2d Cir. 2007) ("Generally, the meaning and truthfulness of a defendant's statement is a question of fact for the 122 EF

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

States v. Tranquillo, 606 F. Supp. 2d 370 (S.D.N.Y. 2009) 284 United States v. Trippe, 171 F. Supp. 2d 230 (S.D.N.Y. 2001) 267 United States v. Triumph Capital Group, Inc., 237 F. App'x 625 (2d Cir. 2007) 184, 187 United States v. Turoff, 853 F.2d 1037 (2d Cir. 1988) 204 United States v. Ulbricht, No. 14 Cr. 68 (

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 are properly put to the jury and not a basis to dismiss the counts pretrial and without the benefit of a complete record. See United States v. Triumph Capital Group, Inc., 237 F. App'x 625, 627-28 (2d Cir. 2007) ("Generally, the meaning and truthfulness of a defendant's statement is a question of fact for the 122 EF

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

States v. Tranquillo, 606 F. Supp. 2d 370 (S.D.N.Y. 2009) 192 United States v. Trippe, 171 F. Supp. 2d 230 (S.D.N.Y. 2001) 175 United States v. Triumph Capital Group, Inc., 237 F. App'x 625 (2d Cir. 2007) 122, 125 United States v. Turoff, 853 F.2d 1037 (2d Cir. 1988) 138 United States v. Urena, 989 F. Supp. 2d 25

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

ts are properly put to the jury, and should not be subject to resolution on a motion to dismiss based on an incomplete record. See United States v. Triumph Capital Group, Inc., 237 F. App'x 625, 627- 28 (2d Cir. 2007) ("Generally, the meaning and truthfulness of a defendant's statement is a question of fact for the jury.")

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 are properly put to the jury and not a basis to dismiss the counts pretrial and without the benefit of a complete record. See United States v. Triumph Capital Group, Inc., 237 F. App'x 625, 627-28 (2d Cir. 2007) ("Generally, the meaning and truthfulness of a defendant's statement is a question of fact for the 122 EF

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

States v. Tranquillo, 606 F. Supp. 2d 370 (S.D.N.Y. 2009) 284 United States v. Trippe, 171 F. Supp. 2d 230 (S.D.N.Y. 2001) 267 United States v. Triumph Capital Group, Inc., 237 F. App'x 625 (2d Cir. 2007) 184, 187 United States v. Turoff, 853 F.2d 1037 (2d Cir. 1988) 204 United States v. Ulbricht, No. 14 Cr. 68 (