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original memorandum, that Defendant EPSTEIN may not contest this Court's jurisdiction based on the Non Prosecution Agreement ("NPA"). Although the State Court action is not a part of this Complaint, and is not alleged in the four (4) corners of it, it is a fact that cannot be contested since Plaintiff has
the issue and determined travel is not necessary to sustain such a conviction. In United States v. Bailey 228 F.3d 637, 639-40 (6th Cir. 2000), the Sixth Circuit affirmed a conviction under Section 2422(b) where the defendant sent e-mails proposing oral sex and attempted to set up meetings with minor females
), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding ...that no exceptional circumstances require dismissal of this case in deference to the pending state c
the issue and determined travel is not necessary to sustain such a conviction. In United States I. Bailey 228 F.3d 637, 639-40 (6th Cir. 2000), the Sixth Circuit affirmed a conviction under Section 2422(b) where the defendant sent e-mails proposing oral sex and attempted to set up meetings with minor females
), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding ...that no exceptional circumstances require dismissal of this case in deference to the pending state c
he issue and determined travel is not necessary to sustain such a conviction. In United States v. Bailey, 228 F.3d 637, 639-40 (6th Cir. 2000), the Sixth Circuit affirmed a conviction under Section 2422(b) where the defendant sent e-mails proposing oral sex and attempted to set up meetings with minor females
Entities connected to both State Court and Sixth Circuit

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Jay Lefkowitz
PERSONScott Rothstein
PERSON
Prince Andrew
PERSONRoy Black
PERSON
the United States District Court
ORGANIZATION