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the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement.
ed Jane Doe 1 and Jane Doe 2 (and several other victims) in civil suits against Jeffrey Epstein for injuries my clients suffered as a consequence of Jeffrey Epstein's sexual abuse of them. 2. I have previously filed an affidavit in this matter (see DE 225-1). This affidavit repeats some of the information contai
Undisputed Fact 1 ("Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls,
she, herself] procured additional young women for Mr. Epstein and [was] paid commissions or referral fees for
fense to the equitable claim of estoppel is the doctrine of 'unclean hands."' Bird v. Centennial Ins. Co‘, 11 F.3d 228, 234 (1st Cir. 1993) (citing Peabody Gas & Oil Co. v. Standard Oil Co., 284 Mass. 87, 187 N.E. 112, 113 (1933) ("[O]ne must come into a court of equity with clean hands in order to secure relief...."
15 (quoting former First Assistant U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Interve
Page: EFTA00021449 →r determining remedy, neither party disputes that Mr. Epstein has a right to be heard . . . . Mr. Epstein resp
Page: EFTA00021451 →igation. As Epstein's own exhibits makes clear, the release covers only claims for "compensatory or punitive damages": [Jane Doe] individually, and Jeffrey Epstein, individually (jointly referred to as "Parties"), enter into this Settlement Agreement and General Release ("Settlement Agreement") in order to res
Page: EFTA00021485 →RECEIVED PROCEDURAL DUE PROCESS THROUGH AN OPPORTUNITY TO BE HEARD AND SUBMIT EVIDENCE ON ISSUES PERTAINING TO REMEDIES. 6 A. As an Intervenor, Epstein Has Received Procedural Due Process 6 B. The Court's Findings About Epstein Counsel's Awareness of Concealment of the Non- Prosecution Agreement a
Page: EFTA00022547 →15 (quoting former First Assistant U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Interve
Page: EFTA00022553 →r determining remedy, neither party disputes that Mr. Epstein has a right to be heard . . . . Mr. Epstein resp
Page: EFTA00022555 →Entities connected to both Jeffrey Epstein and Peabody Gas & Oil Co.

Marc Rich
PERSON
Madison
LOCATION
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Paul Cassell
PERSON
Jeffrey Sloman
PERSONCraig Martin
PERSON
Supreme Court
ORGANIZATION
New Hampshire
LOCATION
the University of Utah
ORGANIZATIONGarcia
PERSON
Maine
LOCATIONDistrict Court for the Southern District of New York
ORGANIZATIONU.S. Attorney's Office
ORGANIZATION
Hunter Biden
PERSON