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

(c) did not include express language about adding plaintiffs because that "problem is generally easier" than adding defendants. Fed. R. Civ. P. 15. Circuit Courts have applied varying tests for articulating how to determine when an amendment relates back to the filing of the original pleading. In the Eleventh

. . 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

(c) did not include express language about adding plaintiffs because that "problem is generally easier" than adding defendants. Fed. R. Civ. P. 15. Circuit Courts have applied varying tests for articulating how to determine when an amendment relates back to the filing of the original pleading. In the Eleventh

. . 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

(c) did not include express language about adding plaintiffs because that "problem is generally easier" than adding defendants. Fed. R. Civ. P. 15. Circuit Courts have applied varying tests for articulating how to determine when an amendment relates back to the filing of the original pleading. In the Eleventh

. . 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

(c) did not include express language about adding plaintiffs because that "problem is generally easier" than adding defendants. Fed. R. Civ. P. 15. Circuit Courts have applied varying tests for articulating how to determine when an amendment relates back to the filing of the original pleading. In the Eleventh

From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Insider Trading

below. Alex Gelinas, Daniel G. Viola, Danielle Epstein-Day, Douglas Hirsch, Jeffrey Goldberg, Jennife

From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Insider Tra

upreme Court very little reason to re-visit Dirks. Further, the Newman decision did not explicitly identify a Circuit-Split with decisions by other Circuit Courts, which is the primary basis for obtaining Supreme Court review. So although Newman does create some tension with the insider trading rulings of othe