Epstein Secrets

rty. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress

l. ¶ 5, DE 361-26.) Jane Doe 1's understanding was that the federal investigation would continue. (Jane Doe 1 Decl. 16.) In contrast, Special Agent Kuyrkendall stated that the meeting with Jane Doe 1 was to advise her of the main terms of the NPA.2 (Kuykendall Decl. ¶ 8, DE 403-18.) After the meeting, Speci

he provision about monetary damages could be grounds for impeachment of the victims and herself. (Kuykendall Decl. ¶ 9.) According to Special Agent Kuyrkendall, the investigation of Epstein continued through 2008. (Kuykendall Decl. ¶ 11.) In addition to Jane Doe I, FBI agents only talked to two other victim

disputes. Construing the CVRA in the way that 'See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States v. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United States, distri

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafaiia]. (See DE14, Exs. 1 and 2.) It is further undisputed that Jane Doe #1 actually took advantage of the offer of protection when E

ane Doe #1] and August 2006 [Jane Doe #2] wherein they were advised of this right and given the phone numbers of AUSA Villafafia, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners felt that they were "being threa

disputes. Construing the CVRA in the way that d'See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States): United States I Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United States, distri

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafaiial. (See DE14, Exs. I and 2.) It is further undisputed that Jane Doe ttl actually took advantage of the offer of protection when

ane Doe #1) and August 2006 [Jane Doe #2) wherein they were advised of this right and given the phone numbers of AUSA Villafafia, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners felt that they were "being threa

r disputes. Construing the CVRA in the way that "See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United States, distri

ane Doe #1] and August 2006 [Jane Doe #2) wherein they were advised of this right and given the phone numbers of AUSA Villafaila, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners felt that they were "being threa

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafafia]. (See DE14, Exs. 1 and 2.) It is further undisputed that Jane Doe #1 actually took advantage of the offer of protection when E

jury to return a verdict for that party. If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted." Anderson.. Liberty Lobby, Inc., 477 U.S. 242, 250, 106 S. Ct. 2505, 2511 (1986) (internal citations omitted). 3 EFTA00211720 and hoped that Epstein would

o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11 6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 5; Ex. S, ¶ 12. Jane Doe No. 2 described he

jury to return a verdict for that party. If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250, 106 S. Ct. 2505, 2511 (1986) (internal citations omitted). 3 EFTA00799827 Case 9:08-cv-80736-KAM Docu

to obtain information from Jane Doe No. 2. Ex. B; Ex. S, 6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, I 5; Ex. S, q 12. Jane Doe No. 2

jury to return a verdict for that party. If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250, 106 S. Ct. 2505, 2511 (1986) (internal citations omitted). 3 EFTA00591464 Case 9:08-cv-80736-KAM Docu

o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11[6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 15; Ex. S, ¶ 12. Jane Doe No. 2 d

y probative, summary judgment is proper. See Sainz v. Cabarceno Enterprises, Inc., No. 14-20608-CIV, 2015 WL 12551061, at *1 (■. Fla. 2015) (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986)). The undisputed facts recited above plainly establish that the Government—with the knowledge of, a

cription of the meeting, but 8 EFTA00597325 Case 9:08-cv-80736-KAM Document 417 Entered on FLSD Docket 08/11/2017 Page 9 of 33 citing only Agent Kuyrkendall's declaration recounting what he said, not what understanding Jane Doe I had). The parties agree that, during the time period before Epstein's entr

apply not only to references to unindicted co-conspirators in indictments and factual proffers, but also to motion papers. See, e.g., United States. Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999) ("After carefully reviewing the government's moving papers on the conflict of interest issue, the court c

ct me or Special Agen Kuyrkendall Sincerely, R. Alexandea United States Attorney By: A. Assistant United States Attorney cc: Special Agent.. Kuyrkendall, F.B.I. Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office US_Atty_Cor_00262 EFTA00184869 Case 9:08-cv-80736-KAM Document