139 H3vlgiu2 ih that is one of the reasons why in the Second Circuit they think 2 this is a good rule of law, because they approve of the result 3 that the Fifth Circuit reached in that co-conspirator case. 4 And LiButti then goes on, as your Honor is well 5 familiar, with laying out four different factors. The first is 6 the nature of the relationship involved. The relationship here 7 is co-conspirators. They're in the immediate next echelon of 8 the conspiracy. They are direct reports in the business sense, 9 although this is a criminal enterprise, but Kellen and 10 Marcinkova are direct reports to Ms. Maxwell. Of course the 1a conspiracy continues. This is not just at the time of those 12 events. The conspiracy continues to today, and your Honor is 13 familiar with that from the fact that they were evading service 14 while we were trying to obtain their testimony last year. 15 Eventually they show up with lawyers, a Bruce Reinhart I think 16 is an Epstein lawyer; I think at some point Ms. Marcinkova had de Mr. Goldberger, who's an attorney for Mr. Epstein now. They've 18 both made significant efforts to evade service. Why? Because 19 in our view the conspiracy continues to this day. The 20 conspiracy is trying to conceal what was done to girls in 21 Florida over an extended period of time. The concealment 22 continues through the efforts not only of the defendant but 23 also through the efforts of Kellen and Marcinkova. 24 But there's more that binds them together even today. 25 Your Honor is of course familiar with the nonprosecution SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011442