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ly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, the Government has unclean hands for multiple reasons — as argued at length in the victims' summary judgment moti
position would create the perception that either the earlier or later court was misled." DE 401-2 at 25 (emphasis added) (citing Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the state court proceedings as the "earlier" proceedings, the Government does n
rly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, Epstein — a sex offender who worked with the USAO-SDFL to illegally conceal an 47 EFTA00021491 --- PAGE BREAK
Page: EFTA00021492 →al acceptance of the inconsistent later position would create the perception that either the earlier or later court was misled." Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the filing of a civil court complaint as an earlier "proceeding," Epstein does n
Page: EFTA00021495 →rly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, Epstein — a sex offender who worked with the USAO-SDFL to illegally conceal an 47 EFTA00022595 --- PAGE BREAK
Page: EFTA00022596 →al acceptance of the inconsistent later position would create the perception that either the earlier or later court was misled." Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the filing of a civil court complaint as an earlier "proceeding," Epstein does n
Page: EFTA00022599 →Entities connected to both Yellow Cab Transit Co. and HDR Engineering, Inc.

Department of Justice
ORGANIZATION
United States
LOCATION
Kenneth Marra
PERSON
Jeffrey Epstein
PERSONJacqueline Perczek
PERSON
Paul Cassell
PERSON
Bradley Edwards
PERSONthe Eleventh Circuit
ORGANIZATION
the University of Utah
ORGANIZATION
Alexander Acosta
PERSON
New Hampshire
LOCATION
Maine
LOCATION
Slater
PERSONAjaka
PERSONStandard Oil Co.
ORGANIZATIONRoy Eric Black
PERSONMohasco Corp.
ORGANIZATION
Michael Cohen
PERSONPeabody Gas & Oil Co.
ORGANIZATION
Executive
ORGANIZATION