Epstein Secrets

) and 12(b)(6). I. PRELIMINARY STATEMENT: MULTIPLE SDNY JUDGES WARNED THE PERSON DRIVING THIS ACTION AGAINST SUCH FRIVOLOUS LAWSUITS Judges Sweet, Berman and Castel warned Steven Hoffenberg ("Hoffenberg"), whom Plaintiffs identify as the "Non-Party Affiant" (Compl. 15) and whose affidavit forms the e

as Ex. E to the Moskowitz Decl. 6 A true and correct copy of the Order is attached as Ex. F to the Moskowitz Decl. 7 A true and correct copy of the Petition is attached as Ex. G to the Moskowitz Decl. 8 See Complaint, Hoffenberg v. Epstein, No. I: 1 &cv-03989-RJS (S.D.N.Y. May 27, 2016). -2- EFTA0080245

nited States Courthouse (212) 805-6715 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe ATCPTOC A JOiiNSON ..n We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of condi

pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject matter jurisdiction.1 This Court lacks subject matter jurisdiction over the Petition because See, e.g., Gnipo Dataflux v. Atlas Global Group, L.P., 541 U.S. 567, 571 (2004) ("Challenges to subject-matter jurisdiction can of course b

nited States Courthouse (212) 805-6715 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe SttPtOt • JOHNSON ttP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of condit

pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject matter jurisdiction.1 This Court lacks subject matter jurisdiction over the Petition because See, e.g., Gnipo Dataflux v. Atlas Global Group, L.P., 541 U.S. 567, 571 (2004) ("Challenges to subject-matter jurisdiction can of course b

7 BY MR. TEIN: 8 Q. Have you ever seen that picture before? 9 A. Yes. 10 Q. Is that a picture of your father, your 11 stepmother and Mr. Berman at the press conference 12 regarding your lawsuit? 13 A. Yes. 14 Q. Now you know that this is a very serious 15 matter, don't you? 16 MR.

imity among the defendants. In accordance with 28 U.S.C. § 1446(6) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties,

for this deposition. 18 BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. 20 A. Yes. 21 O. Thank you. 22 In fact, you know that Mr. Berman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 A. After it happened. Ph. - Fax.

imity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties,