6
Shared Docs
5
Same-Page
24 / 6
Mentions
, vs UNITED STATES OF AMERICA, Respondent. I JEFFREY EPSTEIN, Intervenor. I INTERVENOR JEFFREY EPST
PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES A. Mr. Epstein was not a Party to the Underlying Litigation and
o prosecuting what was, at heart, a local sex abuse case." See Jeffrey Sloman, Alex Acosta Acted with Professionalism and Integrity in Handling the Jeffrey Epstein Case, Miami Herald Op-Ed, Feb. 15, 2019. The USAO-SDFL's decision to enter into the NPA was also influenced by its consideration of the privacy interest
EEMENT 1 EFTA00299022 TABLE OF CONTENTS INTRODUCTION BACKGROUND ARGUMENT I. PRINCIPLES OF PROCEDURAL DUE PROCESS PRECLUDE IMPOSITION OF THE EPSTEIN REMEDIES A. Mr. Epstein was not a Party to the Underlying Litigation and There is no Judgment Against him B. There is no Judicial Finding of "Bad
teenth Judicial Circuit in and for Palm Beach County on one count of solicitation of prostitution, in violation of Fla. Stat. §796.07. See State v. Jeffiey E. Epstein, 50-2006-CF-009454-AXXX-MB. In or around November 2006, while the state court charge was pending, Mr. Epstein learned that the United States Attorn
taneously attempting to avoid the burdens that contract imposes." Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (1 1 th Cir. 2005), citing Humana, 285 F.3d at 976. Petitioners claimed the benefit of the NPA in multiple civil lawsuits. After successfully concluding those lawsuits, Petitioners
the type of entity of the sole Member (Le., Individual, corporation, partnership, etc.) is: NAME. U.S. CITIZENSHIP TYPE OF ENTITY VERIFICATION Jeffrey E. Epstein Individual YES X NO S. The LLC Is managed by a Manager. 6. The managers, members or officers of this LLC may act Independently Y&.N_ 7. The
h Term Q Ar Sonde Search 0 search JEFFREY E EPSTEIN 0 hemmed sewn tic seam a new name Q Menu se
OW BILLING INFORMATION Aircraft Descriptions: N JE Buyer: i-lvocrion Air Lit_ O Seller: hst vio
41 Search Term Q Ar Sonde Search 0 search JEFFREY E EPSTEIN 0 hemmed sewn tic seam a new name Q M
U.S. CITIZENSHIP TYPE OF ENTITY VERIFICATION Jeffrey E. Epstein Individual YES X NO S. The LLC Is ma
e consumer-focused brand. The logo was designed by New York-based Siegel+Gale.(411 2016 On July 3, 2015, Aetna announced that it planned to acquire Humana for US$37,000,000,000 in cash and stock,(42) or US$230 a share(43) Aetna and Humana shareholders would have owned 74% and 26% of the new combined oo
ITIONERS ARE EQUITABLY ESTOPPED FROM CHALLENGING THE NPA On September 10, 2008, Jane Doe No. 1 filed an action in Palm Beach County, Florida, E.W. I. Jeffrey Epstein, Case No. 50-2008-CA-028058-XXXXMB, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. P. On September 11, 2008, Jane Doe No.
r than to assert that Jeffrey Epstein sexually abused both. However, the differing circumstances of the two petitioners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' Jane Doe No. 2 r
0. When asked whether Epstein "pulled you closer to him in a sexual way," Jane Doe No. 2 replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. Id. at 22. At the end of her interview, Jane Doe No. 2 was asked if she had any questions for the agents or AUSA Id. at 57
agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email
aneously attempting to avoid the burdens that contract imposes." Blinco I. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (1 I th Cir. 2005), citing Humana, 285 F.3d at 976. As third-party beneficiaries of the NPA, petitioners claimed the benefit of the NPA in their state court damage claims against Eps
s from Jeffrey Epstein for sexually abusing her. Ex. P. On September 11, 2008, Jane Doe No. 2 file an action in Palm Beach County, Florida, L.M. v. Jeffrey Epstein Case No. 50-2008-CA- 28051-XXXXMB, seeking money damages from Jeffrey Epstein for sexually abusing her. Ex. Q. 6 "A judicial admission is a formal conce
r than to assert that Jeffrey Epstein sexually abused both. However, the differing circumstances of the two petitioners during the investigation of Epstein are highly relevant in determining whether each petitioner can even invoke the CVRA. Through her attorney, James Eisenberg, Esq.,' Jane Doe No. 2 r
0. When asked whether Epstein "pulled you closer to him in a sexual way," Jane Doe No. 2 replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. Id. at 22. At the end of her interview, Jane Doe No. 2 was asked if she had any questions for the agents or AUSA Villafafia
agreement entered into by the United States and Mr. Epstein in a timely fashion." Ex. N, Nov. 27, 2007 email
ultaneously attempting to avoid the burdens that contract imposes." Blinco v. Green Tree Servicing LLC 400 F.3d 1308, 1312 (11th Cir. 2005), citing Humana, 285 F.3d at 976. As third-party beneficiaries of the NPA, petitioners claimed the benefit of the NPA in their state court damage claims against Eps
e. The article noted that in the shadow of gangster James "Whitey" Bulger's 2018 beating death at a West Virginia federal penitentiary and financier Jeffrey Epstein's 2019 suicide at a Manhattan federal jail while awaiting trial on sex trafficking charges, the Bureau of Prisons is again under scrutiny for failing
rginia federal penitentiary and financier Jeffrey Epstein's 2019 suicide at a Manhattan federal jail while
West Virginia federal penitentiary and financier Jeffrey Epstein's 2019 suicide at a Manhattan federal ja
oubles Pile On Adams Foes Begin to Circle • A Mapmaker's Hand-Illustrated Version of a Perfect World Wall Street Journal • Cigna Calls Off Bid for Humana Megadeal • Israel Faces Outcry as Photos Of Detainees in Gaza Emerge • Colleges' Free Speech Policies Draw More Scrutiny • Investor Group Makes Off
20 Cr. 330 (MN) Haddon, Morgan and Foreman, t.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado
Page: EFTA00018749 →nying as "untrue" and "obvious lies'as allegations that Ms. Maxwell participated in a scheme causing her to be "sexually abused and trafficked" by Jeffrey Epstein. Given the amount of personal, confidential material and information sought in discovery, the district court entered a stipulated Protective Order
Page: EFTA00018750 →arrested Ms. Maxwell. On July 8, the government filed a superseding indictment alleging that Ms. Maxwell "assisted, facilitated, and contributed" to Epstein's abuse of minors. Regarding the civil action, the indictment alleges that in 2016 Ms. Maxwell made "efforts to conceal her conduct" by "repeatedly
Page: EFTA00018752 →Entities connected to both Jeffrey Epstein and Humana

Lesley Groff
PERSON
Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Lawrence Krauss
PERSON
Harry Reid
PERSON
Joe Biden
PERSON
Prince Charles
PERSONJane Doe
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON