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d States also 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 abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
) 23 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 62, 72 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00099954 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 166, 169 United States v. Farmer, 137 F.3d 1265 (1
d States also 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 abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
) 23 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 62, 72 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00077619 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) United States v. Fanner, 137 F.3d 1265 (10th Cir. 19
d States also 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 abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
) 23 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 62, 72 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00039434 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) United States v. Fanner, 137 F.3d 1265 (10th Cir. 19
d States also 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 abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
) 19 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 43, 49 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 169 United States v. Ewell, 383 U.S. 116 (1966) 54 xii EFTA00095079 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 113, 114 United States v. Fanner, 137 F.3d 126
y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section
98) ("[N]o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such as occurred in this case."). Cf. Ewell v. Daggs, 108 U.S. 143, 149 (1883) (stating that 'Inlo court will lend its aid to a [plaintiff] who founds [a] cause of action upon an immoral or a
y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section
98) ("[N]o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such as occurred in this case."). Cf. Ewell v. Daggs, 108 U.S. 143, 149 (1883) (stating that "`[n]o court will lend its aid to a [plaintiff] who founds [a] cause of action upon an immoral or
Entities connected to both Sarah Kellen and Ewell

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSONBruce E. Reinhart
PERSON
United States
LOCATION
George W. Bush
PERSONMichael J. Pike
PERSONLeon Black
PERSON
Palm Beach Gardens
LOCATION
Virginia Giuffre
PERSON
A. Marie Villafana
PERSON