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736-KAM Document 416 Entered on FLSD Docket 08/11/2017 Page 23 of 65 So far as appears in the available public materials, Senator Kyl's concern that the Justice Department's policy of conferring with victims about plea agreements before charges were filed would be a "dead letter" went unaddressed. Even today, the Justice
cted with the Justice Department's other statements on combatting sex abuse and trafficking. Attorney General Eric H. Holder Jr. Delivers Remarks at Justice Department Event Marking National Slavery and Human Trafficking Prevention Month (Jan. 29, 2015) http:/Avww.justice.gov/opa/speech/attomey-general-eric-h- holder-jr-
are irrelevant, and we really hope he does not prove the point that a man can commit heinous crimes against children and buy his way out of it. If the Department of Justice's recent commitment to the protection of our children from child molesters is to be more than rhetoric, then this is the time and the case where the
fense to the equitable claim of estoppel is the doctrine of 'unclean hands."' Bird v. Centennial Ins. Co‘, 11 F.3d 228, 234 (1st Cir. 1993) (citing Peabody Gas & Oil Co. v. Standard Oil Co., 284 Mass. 87, 187 N.E. 112, 113 (1933) ("[O]ne must come into a court of equity with clean hands in order to secure relief...."
v. United States, 817 F.Supp.2d 1337, 1341 (S.D. Fla. 2011). Epstein also fails to fully describe what the Justice Department regulations required the Justice Department to do during the investigative stage of a case. The 2005 Attorney General Guidelines for Victim and Witness Assistance (hereinafter "2005 A.G. Victi
Page: EFTA00021457 →1(b)(1) (emphasis added). This Court also previously held that "[w]hile Epstein was within his rights to attempt to persuade higher authorities with the Department of Justice to overrule the prosecutorial decisions of the U.S. Attorney's Office in the Southern District of Florida, the CVRA was designed to give victims the
Page: EFTA00021469 →defense to the equitable claim of estoppel is the doctrine of `unclean hands!" Bird v. Centennial Ins. Co., 11 F.3d 228, 234 (1st Cir. 1993) (citing Peabody Gas & Oil Co. v. Standard Oil Co., 284 Mass. 87, 187 N.E. 112, 113 (1933) ("[O]ne must come into a court of equity with clean hands in order to secure relief....
Page: EFTA00021492 →v. United States, 817 F.Supp.2d 1337, 1341 (S.D. Fla. 2011). Epstein also fails to fully describe what the Justice Department regulations required the Justice Department to do during the investigative stage of a case. The 2005 Attorney General Guidelines for Victim and Witness Assistance (hereinafter "2005 A.G. Victi
Page: EFTA00022561 →1(b)(1) (emphasis added). This Court also previously held that "[w]hile Epstein was within his rights to attempt to persuade higher authorities with the Department of Justice to overrule the prosecutorial decisions of the U.S. Attorney's Office in the Southern District of Florida, the CVRA was designed to give victims the
Page: EFTA00022573 →defense to the equitable claim of estoppel is the doctrine of `unclean hands!" Bird v. Centennial Ins. Co., 11 F.3d 228, 234 (1st Cir. 1993) (citing Peabody Gas & Oil Co. v. Standard Oil Co., 284 Mass. 87, 187 N.E. 112, 113 (1933) ("[O]ne must come into a court of equity with clean hands in order to secure relief....
Page: EFTA00022596 →Entities connected to both Department of Justice and Peabody Gas & Oil Co.

Jeffrey Epstein
PERSON
United States
LOCATION
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Michael Cohen
PERSON
Marc Rich
PERSON
Paul Cassell
PERSON
Supreme Court
ORGANIZATION
Jeffrey Sloman
PERSON
Hunter Biden
PERSON
New Hampshire
LOCATION
Maine
LOCATIONGarcia
PERSON
the University of Utah
ORGANIZATION
Madison
LOCATIONthe Eleventh Circuit
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATIONGuzman
PERSON