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y, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157 (1970). The movant "bears the initial responsibility of informing the district court of the basis for its motion, and identifyin
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
y, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157 (1970). The movant "bears the initial responsibility of informing the district court of the basis for its motion, and identifyin
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
y, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157 (1970). The movant "bears the initial responsibility of informing the district court of the basis for its motion, and identifyin
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 S.H. Kress & Co. and Kuykendall Decl

Anderson
PERSONZenith Radio Corp.
ORGANIZATIONAdickes
PERSON
Jeffrey Epstein
PERSON
United States
LOCATIONLiberty Lobby, Inc.
ORGANIZATIONHerman
PERSON
Kenneth Marra
PERSONFBI
ORGANIZATION
Ken Starr
PERSON
the United States District Court
ORGANIZATION
Ted Babbitt
PERSONStuart Grossman
PERSON
Chris Searcy
PERSONMatsushita Electronic Industrial Co.
ORGANIZATION
Kenna
PERSON
Alexander Acosta
PERSON
Martha Stewart
PERSONWalker
PERSON
Starbucks
ORGANIZATION