HOUSE_OVERSIGHT_011442.jpg

10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 139 H3vlgiu2 that is one of the reasons why in the Second Circuit they think this is a good rule of law, because they approve of the result that the Fifth Circuit reached in that co-conspirator case. And LiButti then goes on, as your Honor is well familiar, with laying out four different factors. The first is the nature of the relationship involved. The relationship here is co-conspirators. They're in the immediate next echelon of the conspiracy. They are direct reports in the business sense, although this is a criminal enterprise, but Kellen and Marcinkova are direct reports to Ms. Maxwell. Of course the conspiracy continues. This is not just at the time of those events. The conspiracy continues to today, and your Honor is familiar with that from the fact that they were evading service while we were trying to obtain their testimony last year. Eventually they show up with lawyers, a Bruce Reinhart I think is an Epstein lawyer; I think at some point Ms. Marcinkova had Mr. Goldberger, who's an attorney for Mr. Epstein now. They've both made significant efforts to evade service. Why? Because in our view the conspiracy continues to this day. The conspiracy is trying to conceal what was done to girls in Florida over an extended period of time. The concealment continues through the efforts not only of the defendant but also through the efforts of Kellen and Marcinkova. But there's more that binds them together even today. Your Honor is of course familiar with the nonprosecution SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011442