Epstein Secrets

RINCESS CmfaPe. AJ41 112 a., kin inn t Cling lien. AShis i. vont 310 SO ICO. ttiti fel l053) 211-033 10S3) 211-011 migolifunpa tHrp (uulut) IP 3.EPSTEIN Royal Princess. Chiang Nal, J8/10/02 IIIIII/IllOtrOAIITO III041141; lit n.dlmnm ellissui o1Da 0.04:41,40 sotoo 12:51 bit (013) 211 -033 WOW (03

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

irms that relation back also "extends by analogy to amendments changing plaintiffs." Fed. R. Civ. P. 15, Adv. Comm. Notes, 1966 Amend. According to the Advisory Committee, the new version of Rule I5(c) did not include express language about adding plaintiffs because that "problem is generally easier" than adding defe

rtedly between Ms. Maxwell and third-party "influential" men whom she allegedly tried to set up on dates, and (b) a witness a woman who worked for Epstein between 2005-06 (after the conclusion of the charged conspiracy) whom the Government said it "may call" at trial. The Government asserted in the Le

ified] documentary evidence relating to the 4 EFTA00105960 charged crimes [and (ii)] her [unspecified] role in scheduling sexualized massages for Jeffrey Epstein with underage girls," apparently in 2005-06. This is hardly the type of "identiff ied]" evidence the Rule contemplates. What "documentary evidence"

RE TO COMPLY WITH THE RULE'S NOTICE REQUIREMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

e Letter makes clear that the witness worked for Mr. Epstein from 2005-06, after the conclusion of the charged

rove, and without explaining the relevance of the evidence for a non- propensity purpose" (id.). 1 EFTA00105957 After December 2020, according to the Advisory Committee, the new subsection (B) requires that: The prosecution must not only identify the evidence that it intends to offer pursuant to the rule but also

. . 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

ement with Jeffrey Epstein and, if so, what crimes were covered. Accordingly, the petition generally alleged that, "[u]pon information and belief, [Epstein] is engaged in plea negotiations with the Office of the United States Attorney for the Southern District of Florida concerning federal crimes he is

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 290-1 at 3 (emphasis added). This descriptio

irms that relation back also "extends by analogy to amendments changing plaintiffs." Fed. R. Civ. P. 15, Adv. Comm. Notes, 1966 Amend. According to the Advisory Committee, the new version of Rule 15(c) did not include express language about adding plaintiffs because that "problem is generally easier" than adding defe

. . 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

ement with Jeffrey Epstein and, if so, what crimes were covered. Accordingly, the petition generally alleged that, "[u]pon information and belief, [Epstein] is engaged in plea negotiations with the Office of the United States Attorney for the Southern District of Florida concerning federal crimes he is

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 290-1 at 3 (emphasis added). This descriptio

irms that relation back also "extends by analogy to amendments changing plaintiffs." Fed. R. Civ. P. 15, Adv. Comm. Notes, 1966 Amend. According to the Advisory Committee, the new version of Rule 15(c) did not include express language about adding plaintiffs because that "problem is generally easier" than adding defe

. . 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

ement with Jeffrey Epstein and, if so, what crimes were covered. Accordingly, the petition generally alleged that, "[u]pon information and belief, [Epstein] is engaged in plea negotiations with the Office of the United States Attorney for the Southern District of Florida concerning federal crimes he is

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 290-1 at 3 (emphasis added). This descriptio

irms that relation back also "extends by analogy to amendments changing plaintiffs." Fed. R. Civ. P. 15, Adv. Comm. Notes, 1966 Amend. According to the Advisory Committee, the new version of Rule 15(c) did not include express language about adding plaintiffs because that "problem is generally easier" than adding defe

as [Trump's] legal team continued to dispute the results." The New York Times <https://wvvw.nytimes.com/live/2020/11/30/us/joe-biden-trump> (11/30, Epstein, Thrush, 18.61M) reports the certification of Biden's 21,000-vote win in Wisconsin "came a few hours after Arizona officials formalized Mr. Biden's

y as this month, public health officials are scrambling to develop guidelines for the equitable allocation of limited vaccine supplies." On Tuesday, the Advisory Committee on Immunization Practices of the Centers for Disease Control and Prevention will meet "to make initial determinations about who gets the first shot