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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 insufficient, the defen
ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 2
he defendant invites the Court to engage in a balancing test that weighs the prejudice to the defendant against the Government's reasons for delay. (Del Mot. 7 at 5,6 n.4). This Court should reject the defendant's invitation. The defendant cites United States v. Brand, 556 F.2d 1312, 1317 n.7 (5th Cir.
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 insufficient, the defen
ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
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 insufficient, the defen
ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
Entities connected to both Lesley Groff and Del Mot

Jeffrey Epstein
PERSONDarren Indyke
PERSON
John F. Kennedy
PERSON
Prince Andrew
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Reid Weingarten
PERSON
Sarah Kellen
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Bill Richardson
PERSONMaria Farmer
PERSON
Bradley Edwards
PERSONMartin Weinberg
PERSONEmmy Taylor
PERSON
Julie K. Brown
PERSON
Ralph Lauren
PERSON
Ken Starr
PERSON
Michael Jackson
PERSON
Florence
LOCATION