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er of law." Fed. R. Civ. P. 56(a). The stringent burden of establishing the absence of a genuine issue of material fact lies with the moving party. 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. Liber
e 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, Special Agent Kuyrkendall became concerned about what would happen if Epstein breached the NPA, and thought th
er of law." Fed. R. Civ. P. 56(a). The stringent burden of establishing the absence of a genuine issue of material fact lies with the moving party. 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. Liber
inue. (Jane Doe 1 Decl. ¶ 6.) In contrast, Special Agent 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, Special Agent became concerned about what would happen if Epstein breached the NPA, and thought that if the vi
er of law." Fed. R. Civ. P. 56(a). The stringent burden of establishing the absence of a genuine issue of material fact lies with the moving party. 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. Liber
that on August 7, 2007, Jane Doe 1 never asked to confer with anyone from the government about charging decisions or any resolution of the matter. (Kuykendall Decl. ¶ 7.) 12 EFTA00098425 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 13 of 33 The United States has a statutory obl
Entities connected to both Celotex Corp. and Kuykendall Decl

United States
LOCATION
Jeffrey Epstein
PERSONWalker
PERSON
Anderson
PERSON
Kenneth Marra
PERSON
the United States District Court
ORGANIZATION
Bradley Edwards
PERSONZenith Radio Corp.
ORGANIZATIONDarby
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSONStuart Grossman
PERSON
Chris Searcy
PERSON
Jeffrey Marc Herman
PERSON
Kenna
PERSON
Martha Stewart
PERSON
Starbucks
ORGANIZATION
Jon Kyl
PERSON
Moussaoui
PERSONMiami-Dade County
LOCATION