Epstein Secrets

rime. The letters specifically advised that if the Petitioners felt that they were "being threatened or harassed, then please contact Special Agent Kuyrkendall or [AUSA Villafaiia]. (See DE14, Exs. 1 and 2.) It is further undisputed that Jane Doe #1 actually took advantage of the offer of protection when E

ane Doe #1] and August 2006 [Jane Doe #2] wherein they were advised of this right and given the phone numbers of AUSA Villafafia, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners felt that they were "being threa

bserved that, "[f]actual admissions can be binding as judicial admissions; admissions of legal conclusions cannot." Id.(citations omitted). See also Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. Ill. 1999)("It is well established that judicial admissions on questions of law have no legal

to obtain information from Jane Doe No. 2. Ex. B; Ex. S, 6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, I 5; Ex. S, q 12. Jane Doe No. 2

s of subordinate employees in the DOJ were considered judicial admissions, a party's judicial admissions on questions of law have no legal effect.6 Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. Ill. 1999). Plainly, at the time the NPA was negotiated in 2007, the then-current version of

o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11[6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 15; Ex. S, ¶ 12. Jane Doe No. 2 d

s of subordinate employees in the DOJ were considered judicial admissions, a party's judicial admissions on questions of law have no legal effect.6 Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. Ill. 1999). Plainly, at the time the NPA was negotiated in 2007, the then-current version of