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, Jane Doe has alleged that Epstein has international contacts, having travelled overseas with such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that he has these international travels? Here again, it is impossible to tell because Epstein has not ex
th such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that h
ive, and opportunity to fraudulently transfer assets.” Jane Doe’s Motion to Restrain Fraudulent Transfer of Assets at 11 (quoting United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001)).2 Epstein completely misses the point of Jane Doe’s means, motive, and opportunity argument, construing it as s
nt incarceration (discussed below), he frequently traveled around the globe in the company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has international contacts, including international financial contacts. See Affidav
f such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable t
a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact tha
ase No. 08-CV-80893-Marra/Johnson Epstein's Memorandum of Law in Opposition to Jane Doe's Injunction Motion Page 8 of 24 close friends with Prince Andrew and therefore it is reasonable to infer Epstein has international financial contacts (Id. 'l[9); (3) Epstein reportedly limited his clients to those
junction Motion Page 8 of 24 close friends with Prince Andrew and therefore it is reasonable to infer Epstein h
Epstein is fraudulently transferring assets because he purportedly has the means, the motive and the opportunity to do so, citing United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001). See Injunction Motion (DE #165) at 11. Sparks is completely inapposite as it concerned whether probable cause fo
orts, Jeffrey Epstein has travelled internationally with Donald Trump, former President Bill Clinton, and Prince Andrew. See, e.g., The Daily Mail, Prince Andrew's Billionaire Friend is Accused of Preying on Girl of 14, Apr. 29, 2007, http://www.dailyznail.co.uldnews/article- 451372/Prince-Andrews-billionaire-f
famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to
a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact tha
oc., 1970, 92, 5625-5640. 32. "(pbd)p Bonding in Phenyltrichloro-tin, -germane, and -silane", Whitesides, G. M., Selgestad, J. G., Thomas, S. P., Andrews, D. W., Morrison, B. A., Panek, E. J. and San Filippo, 3., Jr., J. Organometal. Chem., 1970, 22, 365-374. 31. "The Mechanism of Thermal Decompos
4, 925-930. 371. "Neuraminidase Resistant Hemagglutination Inhibitors: Acrylamide Copolymers Containing a C- Glycoside of N-Acetylneuraminic Acid", Sparks, M. A., Williams, K. W. and Whitesides, G. M., J. Med. Chem., 1993, 36, 778-783. 370. "Synthesis of Methyl a-Sialosides N-substituted with Large A
Entities connected to both Prince Andrew and Sparks

Jeffrey Epstein
PERSON
Marc Rich
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
Bill Clinton
PERSON
United States
LOCATION
George W. Bush
PERSONthe Southern District
LOCATION
Martha Stewart
PERSON
Bradley Edwards
PERSON
George Mitchell
PERSON
Julie K. Brown
PERSON
New York
LOCATION
Harvey Weinstein
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Les Wexner
PERSON
Alfredo Rodriguez
PERSON
Paul Ryan
PERSON