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ncluding cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clea
is designed to prevent federal courts from engaging in such speculation and prematurely and perhaps unnecessarily reaching constitutional issues." Pittman, 267 F.3d at 1280. In these proceedings, the Petitioners have sought to set aside the Non-Prosecution Agreement between Epstein and the USAO-SDFL s
ncluding cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clea
is designed to prevent federal courts from engaging in such speculation and prematurely and perhaps unnecessarily reaching constitutional issues." Pittman, 267 F.3d at 1280. In these proceedings, the Petitioners have sought to set aside the Non-Prosecution Agreement between Epstein and the USAO-SDFL s
- tious under New York law. Robinson, 269 F.3d at 142. In New York, conspiracy and aiding and abetting are varieties of con- certed action liability. Pittman v. Gray- son, 149 F.8d 111, 122 (@d Cir.1998). There must be “(1) an express or tacit agreement to ‘participate in a common plan or design to commit
Page: HOUSE_OVERSIGHT_017862 →may proceed with this claim. Wantanabe Realty Corp. v. City of New York, 01 Civ. 10187(LAK), 2003 WL 22862646, at *4 (S.D.N-Y. Dec. 3., 2003) (citing Pittman, 149 F.3d at 122-28). 8. Negligence [86-88] In New York, a plaintiff may establish negligent infliction of emotional distress under the bystander o
Page: HOUSE_OVERSIGHT_017895 →ge in the publication; (5) special damages, unless actionable per se; and (6) some actual harm so as to warrant compensatory dam- ages. 3. Libel and Slander ¢=30 Under Vermont law, partners in medi- cal practice did not make false and defam- atory statements in telling hospitals that physician had been d
Page: HOUSE_OVERSIGHT_017903 →Entities connected to both Bernie Sanders and Yogananda Pittman

Jeffrey Epstein
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Joe Biden
PERSON
Stephen Hawking
PERSON
Marc Rich
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Barack Obama
PERSON
George Mitchell
PERSON
Michael Jackson
PERSON
Eric Trump
PERSON
Bloomberg L.P.
ORGANIZATION
Prince Charles
PERSON