Epstein Secrets

would contain only facts , not argument, not inferences, not incorrect innuendos. F2 Even after the U.S. Attorney's Office advised Petitioners that the Justice Department's position was that the CVRA's rights only attached upon the filing of federal criminal charges and, hence, that none of the Petitioners' proposed fac

e the trial." Focusing just on the second half of that Rule, for now, as the United States has explained since the very start of the litigation, in Docket Entry No. 19, on August 1, 2008, and as admitted by Petitioners during the hearing on August 14, 2008, no additional facts are needed. The only material f

facts" that Dexter has listed as admitted. In my start of a draft response to DE 49, which I have sent to Dexter, I included the following: We note the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilit

» One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts.") First I would hammer the fact

would contain only facts , not argument, not inferences, not incorrect innuendos. F2 Even after the U.S. Attorney's Office advised Petitioners that the Justice Department's position was that the CVRA's rights only attached upon the filing of federal criminal charges and, hence, that none of the Petitioners' proposed fac

e the trial." Focusing just on the second half of that Rule, for now, as the United States has explained since the very start of the litigation, in Docket Entry No. 19, on August 1, 2008, and as admitted by Petitioners during the hearing on August 14, 2008, no additional facts are needed. The only material f

fied. The court will not embrace such a strained construction of the statute. 5 The government acknowledges that the USAO/SDFL has been recused by the Department of Justice for prospective responsibility of any further criminal investigation or potential prosecution of Epstein relating to his alleged sexual activities w

s MOTION for Hearing filed by United States of America. (Lee, Dexter) (Entered: 04/08/2011) 04/08/201 1 a 04/08/2011 ...... a ) SYSTEM ENTRY — Docket Entry 63 restricted/scaled until further notice. (dj) (Entered: 04/08/2011) 04/08/2011 6 SYSTEM ENTRY — Docket Entry 64 restricted/sealed until further

sed "undisputed material facts" arc in fact disputed and, in many cases, wrong. 'The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the Special Responsibiliti

jury. Pursuant to Fed. R. Crim. P. 6(c), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an

ny of their "facts" that has listed as admitted. In my start of a draft response to DE 49, which I have sent to I included the following: We note the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilit

. One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts.") First I would hammer the fact

sed "undisputed material facts" are in fact disputed and, in many cases, wrong. 2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the SpecialResponsibilitie

jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an

sed "undisputed material facts" are in fact disputed and, in many cases, wrong. 2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the SpecialResponsibilitie

jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an