Epstein Secrets

gment based on the undisputed factual record that has since been developed in this case. 111 /// /// 30 EFTA00211747 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Attorneys for the Government CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 2, 2017, the foregoing Respo

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire I. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

e. / / / I/I I/I 30 EFTA00799854 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 31 of 32 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4th Street, Suite

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

/ / / / / / / 30 EFTA00591491 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 32 of 33 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4'h Street, Suite

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

States respectfully requests that the Application and any Order related to the Application be sealed. Dated: May 30, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ASSISTANT U.S. ATTORNEY Florida Bar No. 500 South Australian Ave, Suite 400 West Palm Beach. Florida 33401 Tel: EFTA00086375 UNITED STATES DI

be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00086459 Case 9:08-cv-