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of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00040739 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work
of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00081333 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work
of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00083566 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work
of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00098414 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work
of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen
ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00794122 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work
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
ictims"), by and through undersigned counsel, pursuant to Fed. R. Civ. P. 56 and Local Rule 56.1, file this response in opposition the Government's Cross-Motion for Summary Judgment (DE 401-2). In support, they state: I. INTRODUCTION As the victims explained in their motion for summary judgment (DE 361), the undispute
cqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Email: pleadingeroyblack.com Attorneys for Jeffrey Epstein Is/ Sway/ p. Seitualua 4 EFTA00591690
ail: pleadingeroyblack.com Attorneys for Jeffrey Epstein Is/ Sway/ p. Seitualua 4 EFTA00591690
3131 Email: pleadingeroyblack.com Attorneys for Jeffrey Epstein Is/ Sway/ p. Seitualua 4 EFTA00591690
time to file a reply/response to the Government's Response and Opposition to the Victims' Motion for Partial Summary Judgment and the Government's Cross-Motion for Summary Judgment (DE 401-2). As the Court is aware, this is a complex case. Following the filing of the Victims' Statement of Undisputed Materials Facts an
e Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 305-371-6421 Fax: 358-2006 Email: Attorneys for Jeffrey Epstein /s/ etadief p. Stioalui4 4 EFTA00618092 Case 9:08-cv-80736-KAM Document 409-1 Entered on FLSD Docket 07/20/2017 Page 1 of 1 UNITED STATES DISTR
421 Fax: 358-2006 Email: Attorneys for Jeffrey Epstein /s/ etadief p. Stioalui4 4 EFTA00618092 Case
05-371-6421 Fax: 358-2006 Email: Attorneys for Jeffrey Epstein /s/ etadief p. Stioalui4 4 EFTA0061809
time to file a reply/response to the Government's Response and Opposition to the Victims' Motion for Partial Summary Judgment and the Government's Cross-Motion for Summary Judgment (DE 401-2). As the Court is aware, this is a complex case. Following the filing of the Victims' Statement of Undisputed Materials Facts an
Entities connected to both Jeffrey Epstein and Cross-Motion for Summary
Leon Black
PERSON
Prince Andrew
PERSON
Eric Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONSouthern District
LOCATIONJane Doe
PERSON
Martha Stewart
PERSON
Barry Diller
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSON
Ken Starr
PERSON
Southern District of New York
ORGANIZATION
Salt Lake City
LOCATION