Epstein Secrets

u./ 4-ittukt Case 7:16-cr-00832-KMK DocuerO nt 120a FlreMS9 l Pace / o zu loud Slew UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA SUPERSEDING INDICTMENT S4 16 Cr. 832 (KMK) NICHOLAS TARTAGLIONE, De

iled 04/16/19 Page 14 of 20 person, other than one of the participants in the offense, and the victim died as a direct result of the act (Title 18, United States Code, Section 3591(a)(2)(C)); e. intentionally and specifically engaged in an act of violence, knowing that the act created a grave risk of - deat

furtherance of the commission of the offense, to wit, TARTAGLIONE and others known and unknown agreed to inveigle, seize, and confine Martin Luna, Urbano Santiago, Miguel Luna, and Hector Gutierrez in and around the Likquid Lounge. Overt Act 13. In furtherance of the conspiracy and to effect the illegal obj

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

61 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

olas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK) (S.D.N.Y.). On A

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

44 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

olas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK) (S.D.N.Y.). On A

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

78 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

olas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK) (S.D.N.Y.). On A

ed such counts. See id. 191 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

ence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is

ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

ence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is

ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

ence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is