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Post, moyes pursuant to Fla, R. Civ. P. 1.510(a) for Summary Judgment and states: I. INTRODUCTION The material facts in this case are not in dispute. Jeffrey Epstein was an extraordinarily wealthy, influential, and serial pedophile. It is indisputable that the State failed or refused to use the tools available to
therwise available in the public record-to inform the public as to whether the then State Attorney for Palm Beach County presented truncated evidence ofEpstein’s criminal wrongdoing to the 2006 grand jury in a manner that precluded Epstein’s indictment for the serious crimes he committed, including sex traff
effrey Epstein, till when he had been informed of Mr. Epstein’s reputation and his wealth, and I just thought t
e material facts in this case are not in dispute. Jeffrey Epstein was an extraordinarily wealthy, influenti
me Court has noted that it is “ofvital importance to maintain the dignity and the integrity of both the grand jury and the presiding judge.” State v. Clemmons, 150 So.2d 231, 233-34 (Fla. 19.63).4“|T]n states such as Florida, where the grand jury is preserved, it is an important appendage ofthe court which
form the basis for Counts Five and Six—to the grand jury in the Southern District of Florida in support of a proposed 60-count federal indictment of Jeffrey Epstein and Sarah Kellen. (Id. at 22:17-31:6). The indictment included a conspiracy count and a substantive count alleging a sex trafficking offense involvi
torney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And remarkably, although interviewed just a few years after she claims any misconduct occurred
LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
5a). "[F]rom 2001 to 2004, [Accuser-4] provided Mr. Epstein with ... over 100 massages and all but three of
n Her Initial Pretrial Motions and Reasserts Them as to the S2 Indictment. 26 CONCLUSION 26 EFTA00103759 TABLE OF AUTHORITIES Page(s) Cases Clemmons v. Delo, 124 F.3d 944 (8th Cir. 1997) 25 Jones v. Jago, 575 F.2d 1164 (6th Cir. 1978) 25 Ex Parte Lange, 85 U.S. (18 Wall.) 163 (1873) 18 No
orn/2020/09/30/us/elections/with-remarlcs- about-poll-watchers-and-the-supreme-court-trump-stepped-up-attempts-to-sow-doubt-on-the-vote.html> (9/30, Epstein, Thrush, 18.61 M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre- emptively argued that Democratic elections
me/ashanti-billie-mother-reacts-to-ruling-working-to- push-additional-legislation/291-a322a0d1-2691-4ee6-adaa-25a350fbaecl> Hampton Roads, VA (9/30, Clemmons, 49K) reports, "Ashanti's mother, Brandy Billie-Moore said the family is devastated by the ruling. `It's not what we were expecting,' Billie-Moore s
included the involvement of top officials, including the president and Vice President Mike Pence." In a separate artide, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections
use and stalking. According to court documents filed by his lawyers, Brown has been diagnosed with schizophrenia." WVEC-TV Hampton Roads, VA (9/30, Clemmons, 49K) reports, "Ashanti's mother, Brandy Billie-Moore said the family is devastated by the ruling. 'It's not what we were expecting,' Billie- Moore
included the involvement of top officials, including the president and Vice President Mike Pence." In a separate article, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections
use and stalking. According to court documents filed by his lawyers, Brown has been diagnosed with schizophrenia." WVEC-TV Hampton Roads, VA (9/30, Clemmons, 49K) reports, "Ashanti's mother, Brandy Billie-Moore said the family is devastated by the ruling. 'It's not what we were expecting,' Billie- Moore
included the involvement of top officials, including the president and Vice President Mike Pence." In a separate article, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections
use and stalking. According to court documents filed by his lawyers, Brown has been diagnosed with schizophrenia." WVEC-TV Hampton Roads, VA (9/30, Clemmons, 49K) reports, "Ashanti's mother, Brandy Billie-Moore said the family is devastated by the ruling. 'It's not what we were expecting,' Billie- Moore
Entities connected to both Jeffrey Epstein and Clemmons

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Boris Nikolic
PERSON
Eric Trump
PERSON
George Mitchell
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
United States
LOCATION
Lawrence Krauss
PERSON
Condoleezza Rice
PERSONPeggy Siegal
PERSON
Stephen Hawking
PERSON
Joe Biden
PERSON
Larry Summers
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON
Julie K. Brown
PERSON