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Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of
010) 22 United States v. Ready, 82 F.3d 551 (2d Cir. 1996) 12 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 20, 21, 23 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 22 United States v. Sattar, No. 02 Cr. 395 (JGK), 2003 WL 22510398 (S.D.N.Y. Nov. 5, 2003) 29 United States v. Van
1982), and that complete accuracy is of "crucial importance," United States v. Kopstein, 759 F.3d 168, 172 (2d Cir. 2014) (quoting United States v. Lefkowitz, 284 F.2d 310, 314 (2d Cir. 1960)). Portions of the requested instruction were unresponsive, portions were redundant, and portions were legally ina
a single conspiracy can contain multiple objectives, particularly if the objectives share important similarities, as they do here. United States v. Salameh, 152 F.3d 88, 148 (2d Cir. 1998) (citing United States v. 4/Irani, 968 F.2d 1512, 1518 (2d Cir. 1992)). Overlap of participants. The participants i
Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of
010) 22 United States v. Ready, 82 F.3d 551 (2d Cir. 1996) 12 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 20, 21, 23 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 22 United States v. Sattar, No. 02 Cr. 395 (JGK), 2003 WL 22510398 (S.D.N.Y. Nov. 5, 2003) 29 United States v. Van
Entities connected to both Jay Lefkowitz and Salameh

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONRoy Black
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Jeffrey Sloman
PERSONMartin Weinberg
PERSON
Ken Starr
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONGerald Lefcourt
PERSONFBI
ORGANIZATION
Lesley Groff
PERSON
Paul Cassell
PERSON