Epstein Secrets

curiam) 18 Lee v. Department of Justice 413 F.3d 53 (D.C. Cir. 2005) 2 L.W. ex rel. Whitson v. Knox County Bd. of Educ. 36 Media L. Rep. 1721 (E.D. Tenn. 2008) 5 Medina v. United Christian Evangelistic Ass'n No. 08-22111-CIV, 2009 WL 5066675 (S.D. Fla. Dec. 15. 2009) 6 New York Times Co. v. Gonzales,

ed on April 13.2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in favor") (see other examples Carroll Reply

tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (- Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of statement

curiam) 18 Lee v. Department of Justice 413 F.3d 53 (D.C. Cir. 2005) 2 L.W. ex rel. Whitson v. Knox County Bd. of Educ. 36 Media L. Rep. 1721 (E.D. Tenn. 2008) 5 Medina v. United Christian Evangelistic Ass'n No. 08-22111-CIV, 2009 WL 5066675 (S.D. Fla. Dec. 15. 2009) 6 New York Times Co. v. Gonzales,

d on April 13, 2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in Jane Doe's favor") (see other examples Carr

tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (Doe's Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of state

S.D.N.Y. 2005) (Preska, J.). 4. Annexed hereto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 1721 (E.D. Tenn. 2008). 5. Annexed hereto as Exhibit C is the Supplementary Affidavit of George Rush in this proceeding, sworn to on April 30, 2010. 6. Jane Doe's bri

for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and "[y]ou digitally penetrated Plaintiff when she was a minor," SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of

S.D.N.Y. 2005) (Preska, J.). 4. Annexed hereto as Exhibit B is a true and correct copy of L.W. v. Knox County Bd. of Educ.. 36 Med. L. Rptr. 1721 (E.D. Tenn. 2008). 5. Annexed hereto as Exhibit C is the Supplementary Affidavit of George Rush in this proceeding, sworn to on April 30, 2010. 6. Jane Doe's bri

tein's silence in the face of such confrontational Requests for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of