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Y EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EP
in the woe position as they would have been had Mr. Epstein been convicted al trial. No more; no less. From
hearing shall be limited to the issue of whether Defendant Epstein's defense of the civil actions filed against him
of Breach USAO No. 2006R0 181 June 9, 2009 To Jeffrey H. Sloman Acting United States Attorney Robert
TATES ATTORNEY Dated: By: Dated: Dated: Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Case No. 08-80736-CV-MARRA P-011815 EFTA00192861 By signing this Addendum, Epstein assert
05/26/2009 Page 3 of 36 absence of a predicate conviction, the FAC not only fails to meet the modest pleading standards elucidated by Twombly and Tribal, but—even taken as true--would not establish a legally "plausible" claim that Plaintiff is a victim of any predicate criminal offense giving rise to
Alabama Police On Newly Opened Training Facility. Other FBI News • FBI Warns Of Phone Scammers. • Judge Keeps Alive Effort To Unseal FBI Files On Jeffrey Epstein. Other Washington News • Media Analyses: GOP Has Votes To Replace Ginsburg; "Momentum" Favors Lagoa. • GOP To Ask Supreme Court To Limit Mail Voti
Clatchy, "Self-styled public information crusader Angela Clemente sued in May, seeking to force the FBI to release the documents on the grounds that Epstein is now dead, albeit under mysterious circumstances, and that there is an overarching public interest in releasing documents. The Justice Department
• Judge Keeps Alive Effort To Unseal FBI Files On Jeffrey Epstein. Other Washington News • Media Analyses
rize a special behavioral health program for Indians', `S. 3264, A bill to expedite and streamline the deployment of affordable broadband service on Tribal land, and for other purposes', `S. 3937, A bill to amend section 330C of the Public Health Service Act to reauthorize special programs for Indians
Alabama Police On Newly Opened Training Facility. OTHER FBI NEWS • FBI Warns Of Phone Scammers. • Judge Keeps Alive Effort To Unseal FBI Files On Jeffrey Epstein. OTHER WASHINGTON NEWS • Media Analyses: GOP Has Votes To Replace Ginsburg; "Momentum" Favors Lagoa. • GOP To Ask Supreme Court To Limit Mail Voti
Clatchy, "Self-styled public information crusader Angela Clemente sued in May, seeking to force the FBI to release the documents on the grounds that Epstein is now dead, EFTA00149079 albeit under mysterious circumstances, and that there is an overarching public interest in releasing documents. The Jus
• Judge Keeps Alive Effort To Unseal FBI Files On Jeffrey Epstein. OTHER WASHINGTON NEWS • Media Analyses
ize a special behavioral health program for Indians', 'S. 3264, A bill to expedite and streamline the deployment of affordable broadband service on Tribal land, and for other purposes', 'S. 3937, A bill to amend section 330C of the Public Health Service Act to reauthorize special programs for Indians f
omments On Ghislaine Maxwell Case. ABC World News TonightVi (7/21, story 7, 0:20, Muir, 7.14M) reported, "President Trump was asked late today about Jeffrey Epstein's alleged co-conspirator, Ghislaine Maxwell. She pleaded not guilty to sex trafficking charges last week. One of her alleged victims describing her as
led a Thursday conference to discuss the possible unsealing of five different sets of documents relating to a defamation lawsuit against Maxwell by Epstein accuser Virginia Giuffre, whom Maxwell had said was lying." Bloomberg adds, "The possible release is coming as Maxwell's lawyer are trying to tamp d
ked girls as young as 14 for her former boyfriend Jeffrey Epstein." US District Judge Loretta Preska in Ne
es subcommittee hybrid legislative hearing - Indigenous Peoples of the United States Subcommittee legislative hearing on 'H.R. 958, Native Youth and Tribal Officer Protection Act; 'H.R. 6237, PRC for Native Veterans Act, 'H.R. 6535, Coverage for Urban Indian Health Providers Act; and 'H.R. 7119, Alaska
to the FBI and submitted a final report. OPA declined to comment. • Jeffreapstein Death: OPA/NY - Fox News asked for comment on the progress of the Jeffrey Epstein death investigation. OPA, in coordination with New York Division, continues to decline comment. • Samuel Little: OPA - The International Associatio
asked for comment on the progress of the Jeffrey Epstein death investigation. OPA, in coordination with N
Fox News asked for comment on the progress of the Jeffrey Epstein death investigation. OPA, in coordinatio
sive contact, witness tampering, theft/embezzlement, and wire fraud. Anderson was previously indicted in February 2019 on charges of defrauding the Tribal government. • Los Angeles - ADIC Delacourt participated in a news conference with Los Angeles County Sheriff Alex Villanueva to discuss FBI assista
omments On Ghlslalne Maxwell Case. ABC World News TonightVi (7/21, story 7, 0:20, Muir, 7.14M) reported, "President Trump was asked late today about Jeffrey Epstein's alleged co-conspirator, Ghislaine Maxwell. She pleaded not guilty to sex trafficking charges last week. One of her alleged victims describing her as
led a Thursday conference to discuss the possible unsealing of five different sets of documents relating to a defamation lawsuit against Maxwell by Epstein accusers whom Maxwell had said was lying." Bloomberg adds, "The possible release is coming as Maxwell's lawyer are trying to tamp down statements
ked girls as young as 14 for her former boyfriend Jeffrey Epstein." US District Judge Loretta Preska in Ne
es subcommittee hybrid legislative hearing - Indigenous Peoples of the United States Subcommittee legislative hearing on 'H.R. 958, Native Youth and Tribal Officer Protection Act', 'H.R. 6237, PRC for Native Veterans Act, 'H.R. 6535, Coverage for Urban Indian Health Providers Act; and 'H.R. 7119, Alask
On Newly Opened Training Facility. EFTA01658620 OTHER FBI NEWS • FBI Warns Of Phone Scammers. • Judge Keeps Alive Effort To Unseal FBI Files On Jeffrey Epstein. OTHER WASHINGTON NEWS • Media Analyses: GOP Has Votes To Replace Ginsburg; "Momentum" Favors Lagoa. • GOP To Ask Supreme Court To Limit Mail Voti
Clatchy, "Self-styled public information crusader Angela Clemente sued in May, seeking to force the FBI to release the documents on the grounds that Epstein is now dead, albeit under mysterious circumstances, and that there is an overarching public interest in releasing documents. The Justice Department
• Judge Keeps Alive Effort To Unseal FBI Files On Jeffrey Epstein. OTHER WASHINGTON NEWS • Media Analyses
ize a special behavioral health program for Indians', 'S. 3264, A bill to expedite and streamline the deployment of affordable broadband service on Tribal land, and for other purposes', 'S. 3937, A bill to amend section 330C of the Public Health Service Act to reauthorize special programs for Indians f
If entity '4 Individual's last name O Unknown or entity's legal name '5 First name O Unknown 6 Middle name Suffix 7 Gender 8 Alternate Name Epstein Jeffrey 9 Occupation or type of business 9a NAICS Code '10 Address O Unknown •11 City O Unknown •12 State O Unknown '14 Country O Unknown
ame Suffix 7 Gender 8 Alternate Name Epstein Jeffrey 9 Occupation or type of business 9a NAICS Code
epository institution Federal Reserve Board (FRB) 38 If 37a - Casino/Card Club is checked, indicate type (chedc only one) K State licensed casino Tribal authorized casino Card dub '30 Legal name of financial institubon 31 Alternate name, e.g. trade name, DBA 12 EIN *33 Address '34 City *35 Stat
ame O Unknown or entity's legal name '5 First name O Unknown 6 Middle name Suffix 7 Gender 8 Alternate Name 9 Occupation or type of business Epstein Jeffrey 9a NAICS Code '10 Address O Unknown •11 City O Unknown •12 State O Unknown '14 Country O Unknown •15 TIN p Unknown '17 Date of b
nown or entity's legal name '5 First name O Unknown 6 Middle name Suffix 7 Gender 8 Alternate Name 9 Occupation or type of business Epstein Jeffrey 9a NAICS Code '10 Address O Unknown •11 City O Unknown •12 State O Unknown '14 Country O Unknown •15 TIN p Unknown '17 Date of birth 0 U
epository institution Federal Reserve Board (FRB) 38 If 37a - Casino/Card Club is checked, indicate type (chedc only one) K State licensed casino Tribal authorized casino K Card dub K Other '30 Legal name of financial institution Deutsche Bank Trust Company Americas 31 Alternate name, e.g. trade
Entities connected to both Jeffrey Epstein and Tribal
Darren Indyke
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Boris Nikolic
PERSON
Woody Allen
PERSON
John F. Kennedy
PERSON
Eric Trump
PERSON
George Mitchell
PERSONDaphne Wallace
PERSON
Madison
LOCATION
George W. Bush
PERSON
Donald Trump
PERSON
United States
LOCATION
Glenn Dubin
PERSON
Stephen Hawking
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
FedEx
ORGANIZATIONSouthern District
LOCATION