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

ss members as plaintiffs); Otto'. Milwaukee C'nty., No. 07-C-427, 2007 WL 3228118, at '2 (E.D. Wis. Oct. 30, 2007) (additional plaintiffs allowed); Grand Lodge of Pennsylvania' Peters, 560 F. Supp. 2d 1270, 1274 (M.D. Fla. 2008) (Eleventh Circuit Court test satisfied, additional plaintiffs allowed). And the Government appe

. . 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

ass members as plaintiffs); Otto'. Milwaukee Cnty., No. 07-C-427, 2007 WL 3228118, at *2 (E.D. Wis. Oct. 30, 2007) (additional plaintiffs allowed); Grand Lodge of Pennsylvania. Peters, 560 F. Supp. 2d 1270, 1274 (M.D. Fla. 2008) (Eleventh Circuit Court test satisfied, additional plaintiffs allowed). And the Government appe

. . 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

rcraft Co., 2010 WL 5253526, at *10 (S.D. Fla. 2010) (magistrate judge recommendation), adopted in relevant part, 2010 WL 5173152 (S.D. Fla. 2010); Grand Lodge of Pennsylvania, 560 F. Supp. 2d 1270, 1274 (M.D. Fla. 2008). This victims' motion to amend satisfies all three requirements of the Eleventh Circuit's test for rel

. . 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

ircraft Co., 2010 WL 5253526, at *10 (S.D. Fla. 2010) (magistrate judge recommendation), adopted in relevant pan, 2010 WL 5173152 (S.D. Fla. 2010); Grand Lodge of Pennsylvania, 560 F. Supp. 2d 1270, 1274 (M.D. Fla. 2008). This victims' motion to amend satisfies all three requirements of the Eleventh Circuit's test for rel