Epstein Secrets

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in a to 1 $11702 Guest's signature Dale EFTA00188680 Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 20 of 28 11 J.EP.STEIN Royal Princess, Chiang Nal, 19/10/02 13:07 ROYAL PRINCESS O94/4 Alm I U Camir, lJan 114.4. Mon( I)44. A M.A.,. O4.4..44 W1O.4 TA: (0331 201.033

w about if I call you at 2 tomorrow? 1. The CVRA case is a Complaint about whether certain statutory rights were violated by the Govt. The Govt not JE is the defendant. Whether JD 3 or JD 4 are or are not victims is not the test of whether they are proper petitioners: they also must allege a basis

. . in the original pleading." Because the original petition in this case alleged that the Government violated the rights of all the girls who were Jeffrey Epstein's victims, the proposed amendment in this case would relate back to the date the petition was filed: July 7, 2008. This relation back eliminates any s

ered on FLSD Docket 02/06/2015 Page 24 of 28 1, SHOPPERS TRAVEL, INC. SHOPPERS TRAVEL AGENT RS/RS BOOKING RFF ZXL1 07 303 5TH AVENUE NEW YORK J EPSTEIN 457 MADISON AVE 4TH FLOOR NEWYORK NY 10027 DATE: SEP 27 2002 DOE 3 RECORD TERMS; PAYMENT OUE UPON PRESENTATION SINGAPORE AIRLINES 27SEP NEW

nt violated the rights of all the girls who were Jeffrey Epstein's victims, the proposed amendment in this

e entire agreement between the United States and Mr. Epstein." DE 290-I at 3 (emphasis added). This descriptio

tims' all agree. Given entirely reasonable. Indeed, any other course would have been foolhardy. 4 The Government's concession readily distinguishes Center for Biological Diversity v. Hamilton, 453 F.3d 1331 (11th Cir. 2006), which is clearly not an "ancillary criminal proceeding," but rather a civil enforcement action of the

the crime or, if no prosecution is underway, in the district court in which the crime occurred." Since no federal criminal charge was filed against Epstein, petitioners sought relief under the second clause, by filing their emergency petition in the Southern District of Florida on July 7, 2008. Petitio

st Epstein, using the Podhurst Orseck, P.A. law firm, which had been suggested to her in the September 3, 2008 letter. Exhibit B Jane Doe No. 102'. Jeffrey Epstein, Case No. 09-80656-CIV-MARRA (S.D.Fla.). In her complaint against Epstein, Jane Doe #3 stated that she received numerous phone calls from one of Ep

ber 3, 2008 letter. Exhibit B Jane Doe No. 102'. Jeffrey Epstein, Case No. 09-80656-CIV-MARRA (S.D.Fla.).

e entire agreement between the United States and Mr. Epstein." Exhibit A at 3. In January 2009, Jane Doe #3 r

98 Case 9:08-cv-80736-KAM Document 290 Entered on FLSD Docket 01/20/2015 Page 6 of 14 limitations, no period of limitations applies, is refuted by Center for Biological Diversity.' That case dealt with the interpretation of the Endangered Species Act, and in particular, 16 U.S.C. § 1540(g)(1)(C). 453 F.3d at 1334. The Eleven

rosecution is underway, in the district court in which the district in which the crime occurred." Since no federal criminal charge was filed against Epstein, petitioners sought relief under the second clause, by filing their emergency petition in the Southern District of Florida on July 7, 2008. Petitio

e Podhurst Orseck, P.A. law firm, which had been suggested to her in the September 3, 2008 letter. Exhibit B, Jane Doe No. 3 EFTA00210910 102 v. Jeffrey Epstein Case No. 09-80656-CIV-MARRA (S.D.Fla.). In her complaint against Epstein, Jane Doe #3 stated that she received numerous phone calls from one of Epstein'

Exhibit B, Jane Doe No. 3 EFTA00210910 102 v. Jeffrey Epstein Case No. 09-80656-CIV-MARRA (S.D.Fla.).

e entire agreement between the United States and Mr. Epstein." Exhibit A at 3. In January 2009, Jane Doe #3 r

F.2d at 55. Also, petitioners' contention that, because the CVRA contains no statute of limitations, no period of limitations applies, is refuted by Center for Biological Diversity. That case dealt with the interpretation of the Endangered Species Act, and in particular, 16 U.S.C. § 1540(g)(1)(C). 453 F.3d at 1334. The Elevent

8. Moreover, on the facts of this case, the Government's construction leads to an absurd result. As the Court is aware, the Government arranged for Epstein to execute his NPA on about September 24, 2007 — in secret. At that time, the victims could not "assert[] the right to be heard before or during th

ommenced within three years after the disability ceases." 28 U.S.C. § 2401(a) (2012) (emphasis added). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from the time her claim accrued until October 2013, when she returned to the United States. See Ex. I at 3 ("I

d). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from

tims' all agree. Given entirely reasonable. Indeed, any other course would have been foolhardy. 4 The Government's concession readily distinguishes Center for Biological Diversity. Hamilton, 453 F.3d 1331 (11th Cir. 2006), which is clearly not an "ancillary criminal proceeding," but rather a civil enforcement action of the En

ed Micro Devices Inc. American Bar Association Apple Inc. Arctic Cat Inc. Banco Santander SA Bank of America Corp. Barclays PLC Celgene Corp. Center for Biological Diversity Chevron Corp. China International Economic and Trade Arbitration Commission Citigroup Inc. EFTA00025393 --- PAGE BREAK --- misrepresentation

some of the most high-profile cases in the Garden State, including a recent suit against Deutsche Bank AG over its ties to millionaire sex offender Jeffrey Epstein. Read full article » Analysis Salas Attack Highlights Importance Of Judicial Security Past violent attacks on judges and their families have spur

ver its ties to millionaire sex offender Jeffrey Epstein. Read full article » Analysis Salas Attack Hig

ank AG over its ties to millionaire sex offender Jeffrey Epstein. Read full article » Analysis Salas At

ciation B.C. Strategy Ltd. Bipartisan Policy Center Boston Heart Diagnostics Corp. Boy Scouts of America Breckenridge Pharmaceutical Inc. CTIA Center for Biological Diversity Cisco Systems Inc. Conference of State Bank Supervisors Court Square Capital Partners LP DISH Network LLC Defenders of Wildlife Deutsche Telek

n filings last year, and as scrutiny of the industry continues to rise, several sectors deserve to be watched carefully this year, say attorneys at Epstein Becker. Read full article » LEGAL INDUSTRY Analysis ABA Says Industry Regs Need A Rethink, But Will It Matter? The passage of a revised America

oup Inc. Association on American Indian Affairs BB&T Corporation BC Partners BNP Paribas Bank of America Corporation Barclays Investment Bank Center for Biological Diversity Citigroup Inc. Conference of State Bank Supervisors Credit Agricole SA Deer Consumer Products Inc. Defenders of Wildlife Deutsche Bank AG Exp

--- PAGE BREAK --- Labor & Employment Associate Epstein Becker & Green, PC New York. New York Corporate

g Duval & Stachenfeld Earthjustice Edelson PC Epstein Becker Green Gibbons PC Harvey & Binnall Holla

. Ancestry.com LLC Apple Inc. Arch Coal Inc. BNP Paribas SA Backcountry.com BancWest Corp. Bank of America Corp. Barclays PLC Celgene Corp. Center for Biological Diversity Center for Justice Charming Shoppes, Inc. Chipotle Mexican Grill Inc. Citigroup Inc. Clean Air Task Force Commonwealth Edison Co. Communicatio