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notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00799496 Case 9:08-cv-8073
ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, Sarah Kellen, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were
f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00799582 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 90 of 101 Epstein, is thus estopped by his ple
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
lation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00208824 Petitioners' righ
ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were often too yo
f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00208910 Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Compla
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
lation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00081017 Case 9:08-cv-8073
ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, Sarah Kellen, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were
f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00081103 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 90 of 101 Epstein, is thus estopped by his ple
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
lation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00795172 Case 9:08-cv-8073
ling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Defendant, Jeffrey Epstein's mansion. 48. Defendant, Sarah Kellen, also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were
f is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Page 5 of 17 EFTA00795258 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 90 of 101 Epstein, is thus estopped by his ple
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
lation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blinco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00205603 Petitioners' righ
D) see also First Am. Compl. 1 32-33, Doe'. Epstein, Case No. 08-80893-CIV-MARRA (S.D. Fla.) ("assert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Comp
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
ellation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blincol Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti
notice of court proceedings as required by 18 U.S.C. § 3771(a)(2) are frivolous; the only court proceedings that have taken place in connection with Epstein's criminal offenses were state court proceedings involving state criminal offenses, for which the CVRA does not 2 EFTA00205625 Petitioners' righ
D) see also First Am. Compl. 1 32-33, Doe'. Epstein, Case No. 08-80893-CIV-MARRA (S.D. Fla.) ("assert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Comp
ert[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the
nd we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a b
ellation of conveyance was precluded by delay in seeking that remedy and affirmative action evincing election to allow agreement to stand); Blincol Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract while simultaneously attempti
sponse to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeffrey Epstein in 2006, Jane Doe 2 expressed her clear and unequivocal desire not to be treated as a vi
as a victim of his conduct. 22. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged
did not want underage girls providing him massages. D.E. 403-3 at 9. She lamented that Epstein was the subject of a criminal investigation: I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a shame that he has to go through this because he's an
e sole issue before the Circuit Court was whether defendant Epstein was entering pleas of guilty that were voluntary
1 of 33 Green Tree Servicing LLC 400 F.3d 1308 (11'" Cir. 2005), an action where the plaintiffs, Jack Blinco, Jr. and Deborah Blinco, claimed that Green Tree Servicing LLC violated their statutory rights under the Real Estate Settlement Procedures Act (RESPA), 12 U.S.C. § 2605. Mr. Blinco alone had executed a promisso
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
ged Care litigation, 285 F.3d 971, 976 (11'" Cir. 200) (construing provision in arbitration clause entered into by patient with hospital); Bunco v. Green Tree Servicing LLC, 400 F.3d 1308, 1312 (11'h Cir. 2005) (construing provision in 10 The Government raised another estoppel argument earlier, but not the particular cl
sponse to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeffrey Epstein in 2006, Jane Doe 2 expressed her clear and unequivocal desire not to be treated as a vi
as a victim of his conduct. 22. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged
did not want underage girls providing him massages. D.E. 403-3 at 9. She lamented that Epstein was the subject of a criminal investigation: I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a shame that he has to go through this because he's an
e sole issue before the Circuit Court was whether defendant Epstein was entering pleas of guilty that were voluntary
20 of 32 Green Tree Servicing LLC 400 F.3d 1308 (11'" Cir. 2005), an action where the plaintiffs, Jack Blinco, Jr. and Deborah Blinco, claimed that Green Tree Servicing LLC violated their statutory rights under the Real Estate Settlement Procedures Act (RESPA), 12 U.S.C. § 2605. Mr. Blinco alone had executed a promisso
Entities connected to both Jeffrey Epstein and Green Tree Servicing LLC

Marc Rich
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Sarah Kellen
PERSON
Joe Biden
PERSON
Prince Charles
PERSONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
New York
LOCATION
A. Marie Villafana
PERSON
Scarlett Johansson
PERSON