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of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00040739 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157
of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00081333 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157
of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00083566 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157
of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00098414 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157
est 1998 No Claim to Orig. U.S. Govt. Works Not Reported in F.Supp. (Cite as: 1998 WL 159055 (S.D.N.Y.)) United States of America, Plaintiff, v. Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a the Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, Lawrence D. Gerzog, Rob
sion of the building pursuant to the Foreign Missions Act, 22 U.S.C. s 4301 et seq. OFM leased the building to defendant Jeffrey E. Epstein in 1992. Epstein sublet the building to defendant Ivan S. Fisher in 1996, purportedly without the Government's consent. Fisher, in turn, sublet a portion of the bui
N.Y.)) United States of America, Plaintiff, v. Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elisa
N.Y.)) United States of America, Plaintiff, v. Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elisa
task is not to "weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for trial." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). Summary judgment is inappropriate if, resolving all ambiguities and drawing all inference
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
turn a verdict for that party. If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted." Anderson.. Liberty Lobby, Inc., 477 U.S. 242, 250, 106 S. Ct. 2505, 2511 (1986) (internal citations omitted). 3 EFTA00211720 and hoped that Epstein would not be prosecuted can
of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00794122 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157
epositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 (hereinafter, "Petitioners"), at his mansion in Palm Beac
Page: EFTA00010507 →re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
Page: EFTA00010507 →er, "DE 407" at 1 1.) Because EFTA00010507 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
Page: EFTA00010508 →ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Page: EFTA00010510 →epositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 ( hereinafter, "Petitioners"), at his mansion in Palm Bea
Page: EFTA00027666 →re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
Page: EFTA00027666 →er, "DE 407" at 9 1.) Because EFTA00027666 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
Page: EFTA00027667 →ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Page: EFTA00027669 →Entities connected to both Jeffrey Epstein and Liberty Lobby, Inc.

Prince Andrew
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Martha Stewart
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
Palm Beach
LOCATION
Ken Starr
PERSON
Southern District of New York
ORGANIZATIONMarie
PERSONAnn Sanchez
PERSON
the United States District Court
ORGANIZATION
Palm Beach Police Department
ORGANIZATION
Michael Reiter
PERSON