Epstein Secrets

sponse to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeffrey Epstein in 2006, Jane Doe 2 expressed her clear and unequivocal desire not to be treated as a vi

as a victim of his conduct. 22. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged

did not want underage girls providing him massages. D.E. 403-3 at 9. She lamented that Epstein was the subject of a criminal investigation: I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a shame that he has to go through this because he's an

e sole issue before the Circuit Court was whether defendant Epstein was entering pleas of guilty that were voluntary

uestion of law to be decided by this Court. "Statutory interpretation is a matter of law appropriate for resolution on summary judgment." Thomas v. Metropolitan Life Ins. Co. 631 F.3d 1153, 1160 (10th Cir. 2011)(citation omitted). "Issues of statutory interpretation and other matters of law may be decided on motion for su

sponse to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeffrey Epstein in 2006, Jane Doe 2 expressed her clear and unequivocal desire not to be treated as a vi

as a victim of his conduct. 22. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged

did not want underage girls providing him massages. D.E. 403-3 at 9. She lamented that Epstein was the subject of a criminal investigation: I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a shame that he has to go through this because he's an

e sole issue before the Circuit Court was whether defendant Epstein was entering pleas of guilty that were voluntary

uestion of law to be decided by this Court. "Statutory interpretation is a matter of law appropriate for resolution on summary judgment." Thomas v. Metropolitan Life Ins. Co. 631 F.3d 1153, 1160 (10th Cir. 2011)(citation omitted). "Issues of statutory interpretation and other matters of law may be decided on motion for su

FOR PUBLICATION FOR UPLOAD IN THE DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CITIGROUP, INC. d/b/a "CITIGROUP," Defendants. ATTORNEYS: Maria Tankenson Hodge, Esq. Hodge & Francois St

ill grant leave for the plaintiffs to amend their pleadings. I. FACTUAL AND PROCEDURAL BACKGROUND In their amended complaint, Jeffrey E. Epstein ("Epstein") and Financial Trust Company, Inc. ("FTC"] [collectively "plaintiffs"] allege that Citibank, N.A. ("Citibank") and Citigroup, Inc. ["Citigroup"]

AND ST. JOHN FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CI

AND ST. JOHN FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CIT

the plaintiffs for the loans that are the subject of this litigation — and therefore, are subject to this Court's general jurisdiction. See, e.g., Metropolitan Life Ins. Co., 84 F.3d at 569 (finding that "our review of general jurisdiction cases reveals that contacts are commonly assessed over a period of years prior t

ness through Citibank and other units throughout the world. Indeed. during oral argument on these motions, the defendants presented a letter sent to Epstein concerning the loans, identifying the two as linked together as "Citigroup, private bank" and "The Citigroup Private Bank, Citibank, NA." At least a

with the forum [territory] and permits a court to exercise its power in a case where the subject matter of the suit is unrelated to those contacts." Metropolitan Life Ins. Co. v. Robertson•Ceco Corp.. 84 F.3d CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0087593 CONFIDENTIAL SDNY_GM_00233777 EFTA01386059