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not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova." It is only because the vi
ederal immunity not only to Epstein, but also to "any potential co-conspirator of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova." It is only because the victims filed this lawsuit, and the District Court ordered the NPA be produced, that the victims and
is a red herring. Also, the canon of constitutional avoidance does not apply here because the CVRA is plain and unambiguous. See United States v. Stevens 559 U.S. 460, 481, 130 S. Ct 1577, 1591-92, 176 L.Ed.2d 435 (2010) (providing that courts cannot "rely upon the canon of construction that 'ambigu
ll be deferred" provided that Epstein met certain conditions. Additionally, the Agreement extended immunity to Epstein's named co-conspirators, • Lesley Groff, [and ' as well as "any potential co-conspirators" of Epstein's. In return for federal immunity, Epstein agreed to plead guilty to two low-level
y to Epstein's named co-conspirators, • Lesley Groff, [and ' as well as "any potential co-conspirato
opinion invokes the canon of constitutional avoidance, it does not apply here because there is no ambiguity in the CVRA text. See United States v. Stevens. 559 U.S. 460, 481, 130 S. Ct. 1577. 1591-92. 176 L.Ed.2d 435 (2010) (providing that courts cannot 'rely upon the canon of construction that 'ambig
oenas. See Tab 2], September 24, 2007 Non Prosecution A ement. It alsoguarantees that persons identified in the Grand Jury subpoena such as , and Leslie Groff and others will not be prosecuted. The new Grand Jury subpoena clearly violates the Non- Prosecution Agreement. Although Mr. Epstein has exercised
in the Grand Jury subpoena such as , and Leslie Groff and others will not be prosecuted. The new Grand
the relevant federal statutes unambiguously indicate that these statutes wcrc designed to address problems of a national and international Justice Stevens, in his concurring opinion, also acknowledged the Me of lenity, calling the plurality opinion's discussion of that rule "surely persuasive." United
See Tab 21, September 24, 2007 Non Prosecution A reernenThiso_auarantees that persons identified in the Grand Jury subpoena such as Sarah , and Leslie Groff and others will not be prosecuted. The new Grand Jury subpoena clearly violates the Non- Prosecution Agreement. Although Mr. Epstein has exercised
ruction charges, many of the facts I included in that first proffer were hypothesized based upon our discussions and the agents' observations of Ms. Groff. We will need to interview her to confirm the accuracy of those facts. On a second count, we could rely on the incident where Mr. Epstein's private
the relevant federal statutes unambiguously indicate that these statutes were designed to address problems of a national and international Justice Stevens, in his concurring opinion, also acknowled d the rule of lenity, calling the plurality opinion's discussion of that rule "surely persuasive." United
k placeL In October am, amended her complaint to include over 20 corporate entitles associated with Epstein an named ! the additional individuals Lesley Groff and l as enablers021 Kativn Doe. et al. v. Epstein's estate (2019) EFTA00262283 5/19/22.3:62 Enie Ctot) OFFIctAi_vel et Jeffrey Epstein - Li
ein an named ! the additional individuals Lesley Groff and l as enablers021 Kativn Doe. et al. v. Epst
rd. Noel (SAM.); Dicimn. Paul (SAPOL)* Duval, Scott (SAPOL); FeIDtvs, Linda (SAPOI. ); e Peer a1xv i ; Newitt. Philip ($APOI ); Parrott Tan (SAPOLI; Stevens, Grant (SAPOL); Wants. Linda ISAPOLl; MOLeap. Stuart (SAPOL-Pla MIILer, cieor115ARCLIa; Osborn, Thomas (SAPOL); Shanahan :panne (SAPOI ); V4nditto
oenas. See Tab 21, September 24, 2007 Non Prosecution Agreement. It also guarantees that persons identified in the Grand Jury subpoena such i. | and Leslie Groff and others will not be prosecuted. The new Grand Jury subpoena clearly violates the Non- Prosecution Agreement. Although Mr. Epstein has exercised hi
Page: HOUSE_OVERSIGHT_012138 →d in the Grand Jury subpoena such i. | and Leslie Groff and others will not be prosecuted. The new Grand
Page: HOUSE_OVERSIGHT_012138 →f the relevant federal statutes unambiguously indicate that these statutes were designed to address problems of a national and international Justice Stevens, in his concurring opinion, also acknowledged the rule of lenity, calling the plurality opinion’s discussion of that rule “surely persuasive.” United
Page: HOUSE_OVERSIGHT_012146 →Entities connected to both Lesley Groff and Stevens

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Marc Rich
PERSON
Richard Kahn
PERSON
John F. Kennedy
PERSONLarry Visoski
PERSONLeon Black
PERSON
Madison
LOCATION
Woody Allen
PERSON
Prince Andrew
PERSON
George Mitchell
PERSON
Ehud Barak
PERSON
Martin Nowak
PERSONDaphne Wallace
PERSONPeggy Siegal
PERSON
Prince Charles
PERSON
Harry Reid
PERSON
Joi Ito
PERSON
Joe Biden
PERSON
Washington State
LOCATION