tion in the fur- therance of a plan or purpose, and (d) the resulting damage or injury.” Chrysler Capital Corp. T78 F.Supp. at 1267 (quoting Kashi v. Gratsos, 790 F.2d 1050, 1055 (2d Cir.1986)). To warrant the inference that a defendant was a member of the conspira- cy, Plaintiffs must show that “(a) the d
Page: HOUSE_OVERSIGHT_017870 →HOUSE_OVERSIGHT_017904 - HOUSE_OVERSIGHT_017934
ion in the furtherance of a plan or purpose, and (d) the resulting damage or injury.’ ” Chrysler Capital Corp., 778 F.Supp. at 1267 (quoting Kashi v. Gratsos, 790 F.2d 1050, 1055 (2d Cir.1986)). Further, “[t]o warrant the inference that a defendant was a member of the conspiracy, Plaintiffs must show that
Page: HOUSE_OVERSIGHT_017920 →l cases in the interests of justice pending the completion of criminal prosecution. See Landis v. North Am. Co., 299 U.S. 248, 255 (1936); Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir. 1986). Courts routinely grant applications to stay civil proceedings in order to protect a pending criminal case. See,
Page: EFTA00024725 →EFTA00091626
announced its "ongoing" criminal investigation into alleged Epstein "co-conspirators" on the same topic as Plaintiff alleges in this case. Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir.1986) (citing SEC v. Dresser Industries, 628 F.2d 1368, 1375 (D.C.Cir.) (en banc), cert. denied, 449 U.S. 993 (1980)) (
EFTA00097351
civil proceedings pending the completion of parallel criminal prosecutions when the interests of justice seem[ ] to require such action"); Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir. 1986) ("IA] court may decide in its discretion to stay civil proceedings when the interests of justice seem to require
Kashi
PersonSurname reference in documents

Bill Clinton
PersonPresident of the United States from 1993 to 2001 (born 1946)

Ghislaine Maxwell
PersonBritish socialite and sex trafficker, daughter of Robert Maxwell, accomplice of Jeffrey Epstein
Second Circuit
OrganizationU.S. Court of Appeals for the Second Circuit

Jeffrey Epstein
PersonAmerican sex offender and financier (1953–2019)

Michael Cohen
PersonAmerican former attorney and former Republican official

United Kingdom
LocationCountry in north-west Europe

Philadelphia
Location1993 film by Jonathan Demme

Terry
PersonFirst name reference to multiple individuals in Epstein documents

Georgina Chapman
PersonEnglish fashion designer and actress
Darren Indyke
PersonAmerican lawyer, longtime personal attorney and co-executor of Jeffrey Epstein's estate

Houston
LocationSeat of Harris County, and largest city in State of Texas, United States

Atlanta
LocationCapital city of Georgia, United States

Maryland
LocationState of the United States of America
Hustler Magazine, Inc.
OrganizationOrganization referenced in documents

Kenya
LocationCountry in Eastern Africa

U.S. Treasury
OrganizationUnited States Department of the Treasury, executive department of the federal government
the City of New York
LocationTown in New York

Supreme Court
OrganizationHighest court of jurisdiction in the US
Ashton
PersonFirst name reference to multiple individuals in the documents