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moving party "must do more than simply show that there is some metaphysical doubt as to the material facts." Matsushita Electronic Industrial Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986). "A party asserting that a fact cannot be or is genuinely disputed must support the assertion by citing to particular par
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
moving party "must do more than simply show that there is some metaphysical doubt as to the material facts." Matsushita Electronic Industrial Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986). "A party asserting that a fact cannot be or is genuinely disputed must support the assertion by citing to particular par
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
moving party "must do more than simply show that there is some metaphysical doubt as to the material facts." Matsushita Electronic Industrial Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986). "A party asserting that a fact cannot be or is genuinely disputed must support the assertion by citing to particular par
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 Zenith Radio Corp. and Kuykendall Decl

Jeffrey Epstein
PERSON
United States
LOCATION
Anderson
PERSONAdickes
PERSONthe Southern District
LOCATION
the United States District Court
ORGANIZATION
Kenneth Marra
PERSONCelotex Corp.
ORGANIZATIONS.H. Kress & Co.
ORGANIZATIONLiberty Lobby, Inc.
ORGANIZATION
Bradley Edwards
PERSON
Alexander Acosta
PERSON
Chris Searcy
PERSONMatsushita Electronic Industrial Co.
ORGANIZATION
Kenna
PERSON
Martha Stewart
PERSONWalker
PERSON
Starbucks
ORGANIZATION
Jon Kyl
PERSON
Moussaoui
PERSON