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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
rejudice; additional plaintiffs allowed). In fact, some jurisdictions require the opposing party to bear the burden of proving prejudice. See. e.g., Padilla'. Sears. Roebuck & Co., 2012 WL 5505071, at *I (N.D. Cal. 2012). In other jurisdictions, a defendant fails to prove prejudice unless it provides su
bout to blow the whistle on the company. The case is U.S. v. Avenatti, 19-cr-00373, U.S. District Court, Southern District of New York (Manhattan). Epstein Jeffrey Epstein Gave $850,000 to M.I.T., and Administrators Knew NY Times By Tiffany Hsu, David Yaffe-Bellany and Marc Tracy 1/10/2020 The convi
low the whistle on the company. The case is U.S. v. Avenatti, 19-cr-00373, U.S. District Court, Southern District of New York (Manhattan). Epstein Jeffrey Epstein Gave $850,000 to M.I.T., and Administrators Knew NY Times By Tiffany Hsu, David Yaffe-Bellany and Marc Tracy 1/10/2020 The convicted sex offender
"directed by Jeffrey Epstein." In a subsequent email, another official at the lab wrote that "for gift recording purposes, we will not be mentioning Jeffrey's name as the impetus for this gift." Mr. Gates denied that Mr. Epstein had directed grant-making on his behalf, and the firm's report said Mr. Gate
financier. The firm, Goodwin Procter, found that Mr. Epstein made 10 donations from 2002 to 2017, and also vis
ocuments. It was alleged that Jorge Padilla, 33, orchestrated a scheme to solicit investments in a sham family investment office, Dunatos Capital. Padilla, a financial professional registered with the Financial Industry Regulatory Authority, worked throughout the period at issue for large financial ins
RA rights to confer and fairness in cases involving white- collar and other wealthy defendants who commonly engage in pro-charge plea negotiations. Jeffrey Epstein's case illustrates my point. The U.S. Attorney's Office assigned specific attorneys, with AUSA Villafana being the lead prosecutor and primary attorn
rey Epstein. In her petition, Ms. Wild alleges that when federal prosecutors secretly negotiated and entered into a non- prosecution agreement with Epstein in 2007, they violated her rights under the CVRA—in particular, her rights to confer with the government's lawyers and to be treated fairly by the
ized by notorious sex trafficker and child abuser Jeffrey Epstein. In her petition, Ms. Wild alleges that
t resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identif
s only after proceedings have begun, at which point that particular person will presumably be more readily identifiable. Cf. I *1208 Rumsfeld it Padilla, 542 U.S. 426, 434-35, 124 S.Ct. 2711, 159 L.Ed.2d 513 (2004) (holding that the "use of the definite article ... indicates that there is generally
eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio
later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best
titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em
supports respondent's view that "the case" implies a specific adversary proceeding rather than an indefinite ongoing investigation. Cf. Rumsfeld v. Padilla, 542 U.S. 426, 434 (2004) (use of definite article "the person" in 28 U.S.C. 2241's provision regarding a habeas custodian signifies that there is
Expose Epstein Files Fox News (01/30, Shaw) reported that Patel, pledged Thursday to work with a top Republican senator on exposing who worked with Jeffrey Epstein in trafficking and exploiting children. The article noted that Sen. Marsha Blackburn (R-TN), quizzed Patel about how he would handle the Epstein cas
rey Epstein in trafficking and exploiting children. The article noted that Sen. Marsha Blackburn (R-TN), quizzed Patel about how he would handle the Epstein case. The sex-trafficking financier died in 2019 while awaiting trial. Nearly 200 names that had previously been redacted from court documents in a
p Republican senator on exposing who worked with Jeffrey Epstein in trafficking and exploiting children. T
digan), NewsNation (01/31, Ramsey, Dempsey, et al.), Axios (01/30, Saric, Habeshian), CNN (01/30, Rigdon, Stiles, et al.), USA TODAY (01/30, Petras, Padilla, et EFTA00162491 al.), Fox News (01/30, Price, Whitten, Koch), Reuters (01/30, Staff Writer), Aljazeera (01/30, Staff Writer), People (01/30, Bak
eference to the position taken by employees of the Department of Justice (DOJ) in letters to the petitioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ employees relevant to the issue of whether a duty existed under § 3771(a)(5) to consult with petitioners prio
later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (1) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agreement ("NPA") had been signed and (2) despite this, the U.S. Attorney's Office had used its best
titioners, or the defense attorneys representing Jeffrey Epstein. Nor are the subjective beliefs of DOJ em
supports respondent's view that "the case" implies a specific adversary proceeding rather than an indefinite ongoing investigation. Cf. Rumsfeld v. Padilla, 542 U.S. 426, 434 (2004) (use of definite article "the person" in 28 U.S.C. 2241's provision regarding a habeas custodian signifies that there is
ents is the latest priority task for FBI employees, who have also been working on topics like immigration enforcement and redacting files related to Jeffrey Epstein. Conservative Watchdog Sues FBI Over 'Pattern' of Blocking Records Requests The Washington Examiner (10/27, Deese) reported that the Oversight Proj
f African Mining Disaster • Prince Andrew Hosted Epstein, Maxwell and Weinstein at Royal Lodge • The 92-Y
ration enforcement and redacting files related to Jeffrey Epstein. Conservative Watchdog Sues FBI Over 'Pa
tors seeking up to 30 years in prison under Indiana's Level 2 felony guidelines. Additional reporting on the story was provided by IndyStar (10/27, Padilla), New York Post (10/27, Oliveira), WRTV (ABC-6) (10/27, Staff Writer), WTHR (NBC-13) (10/27, Nye), and WLKY (CBS-32) (10/27, Staff Writer). FBI War
Expose Epstein Files Fox News (01/30, Shaw) reported that Patel, pledged Thursday to work with a top Republican senator on exposing who worked with Jeffrey Epstein in trafficking and exploiting children. The article noted that Sen. Marsha Blackburn (R-TN), quizzed Patel about how he would handle the Epstein cas
rey Epstein in trafficking and exploiting children. The article noted that Sen. Marsha Blackburn (R-TN), quizzed Patel about how he would handle the Epstein case. The sex-trafficking financier died in 2019 while awaiting trial. Nearly 200 names that had previously been redacted from court documents in a
p Republican senator on exposing who worked with Jeffrey Epstein in trafficking and exploiting children. T
digan), NewsNation (01/31, Ramsey, Dempsey, et al.), Axios (01/30, Saric, Habeshian), CNN (01/30, Rigdon, Stiles, et al.), USA TODAY (01/30, Petras, Padilla, et al.), Fox News (01/30, Price, Whitten, Koch), Reuters (01/30, Staff Writer), Aljazeera (01/30, Staff Writer), People (01/30, Baker, Adams), Reu
NEWS • Head of FBI New York Office Says He's Retired From the Bureau After Being Ordered to Do So • AG Pam Bondi Says FBI Delivered 'Truckload' of Epstein Files • Director Patel Disputes Whistleblower Revelation About FBI 'Honeypot' Agent Spying on Trump Campaign • Continued Reporting: Dan Bongino Na
ve his Cabinet on his side if he wants to be effective. The author mentioned that in light of the recent disappointment regarding the release of the Jeffery Epstein files, Attorney General Pam Bondi called on Director Patel to release the entirety of the files. According to the author, it is likely not
000 unsecured bond, saw her bond revoked Monday during a hearing before U.S. Magistrate Judge Elizabeth "Betsy" Chestney. Chestney cited evidence of Padilla's "dishonest, deceptive and illegal behavior" while on bond in ruling that she should remain locked up pending her trial. Frontier Airlines Passeng
ristian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
Page: EFTA00028880 →.2d 294 (4th Cir. 1986) 12 United States v. Mariamma Viju (01), No. 3:15-CR-0240-B, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 6 United States v. Padilla, 186 F.3d 136 (2d Cir. 1999) 10 EFTA00028882 --- PAGE BREAK --- United States v. Sattar, 272 F. Supp. 2d 348 (S.D.N.Y. 2003) 17 United Sta
Page: EFTA00028882 →7 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 12 Other Authorities Dienst, J., Valiquette, J., Winter, T., and Fitzpatrick, S. "Jeffrey Epstein Confidante Ghislaine Maxwell Arrested on Sex Abuse Charges." NBC New York. July 3, 2020 15 iii EFTA00028883 --- PAGE BREAK --- Ghislaine Maxw
Page: EFTA00028883 →Entities connected to both Jeffrey Epstein and Padilla

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
John F. Kennedy
PERSON
Joi Ito
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Newark
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSON
Joe Biden
PERSONJane Doe
PERSON
Martha Stewart
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION