Epstein Secrets

ication on appeal." Sou v. Gonzales, 450 F.3d 1, 6 n.11 (1st Cir. 2006) (internal quotation marks and citations omitted here and throughout); accord Johnson v. United States, 734 F.3d 352, 360 (4th Cir. 2013). For internal use only SDNY_GM_00056843 CONFIDENTIAL - PURSUANT TO FED. R.ctON(F IDENTIAL DB

d at 821 (holding that party represented by same counsel had "essentially abandoned" argument by making only a "conclusory challenge"); Anderson v. Cagle's, Inc., 488 F.3d 945, 959 (11th Cir. 2007) (same). The "purpose" of the preservation rule is also not served by overlooking Plaintiffs' waiver. Se

per acts by BoA. To the extent Mr. Steadman's claims are predicated on such acts, rather than on Green Tree's acts, they are not viable. 2 See also Johnson v. Fed Home Loan Mort. Corp.. No. C12-1712 TSZ. 2013 U.S. Dist. LEXIS 10485. 2013 WL 308957. at '4 (W.D. Wash. Jan. 25. 2013) ("IAN assignee is liab

14-16.) 12 As aleged. the facts at issue were clearly material. "A material fact is one which would induce the plaintiff to take action." Lawson v. Cagle. 504 So. 2d 226, 227 (Ala. 1987) (citing Bank of Red Bay v. King. 482 So. 2d 274. 282 (Ala. 1985)). and the Plaintiff alleges that BIC's misrepresen

ered on FLSD Docket 05/29/2009 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, VS. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant.

ssociates .„,........—~- Peg* 111 2101 WITIMSS, Never -- at did yew say/ 2 IT M. TCIM: 3 O. You lied agen you went to the creak Muse 4 in Cagle, didn't you? S NA. LIC4014)! OblectIon. Arounentstlwe. 6 Lac of tom:dance, lack of predicate. OP M. TOM: I O. You an ansar the nestle'. 9 A