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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
t party in a previous proceeding.' Judicial estoppel is an equitable concept intended to prevent the perversion of the judicial process." Burnes 1. Pemco Aeroplex, Inc., 291 F.3d 1282, 1285 (11th Cir. 2002) (citation omitted). Judicial estoppel prohibits "parties from deliberately changing positions according to th
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 Pemco Aeroplex, Inc.

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
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONU.S. Attorney's Office
ORGANIZATION
Hunter Biden
PERSONthe Eleventh Circuit
ORGANIZATION