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rs, “Paris Attacks Show Cracks in France’s Counterterrorism Effort,” Wall Street Journal, November 23, 2015 3. “Testimony of General Alexander...”-- Ellen Nakashima,“Officials: Surveillance programs foiled more than 50 terrorist plots.” Washington Post, June 18, 2013 4. “A third NSA program...”-- Glenn
ties, could do immense damage to Western intelligence. Indeed, he said as much once he got to Moscow. In respect to China alone, he told James Risen, the New York Times’ national security reporter, in October 2013 that he had had “access to every [NSA] target, every [NSA] active operation” that could turn out the NSA’
ews with Tyler Drumheller 6. “Snowden’s superior had suspected...”-- Eric Schmitt, “C.L.A. Warning on Snowden in ’09 Said to Slip Through the Cracks, New York Times, October 10, 2013 7. “The discrepancy was explained. ..”—Author’s interview with Source H. 8. “Snowden blamed his career-ending...”— Snowden was int
HOUSE_OVERSIGHT_020421 270 14. “From the 127-page...”--David Larter and Andrew Tilghman, “Military clearance OPM data breach ‘absolute calamity' ,” Navy Times, June 18, 2015 15. “It is next to impossible...”--Bruce Schneier quoted in Homer Jenkins, “The Anti-Hero of Silk Road.” Wall Street Journal, June 3,
THERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants. NOTICE OF REMOVAL July 18, 2008 STEVEN M. LARIMORF CLERK D.S. DIST. CT. S.O. OF FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441
stroy diversity jurisdiction, and to prevent any application of 18 § 3509(k), a mandatory stay provision applicable in federal court 2 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section
¶¶ 29-34). These allegations, however, do not support these claims, or any other theory of liability that would allow recovery against CI Parks v. The New York Times Ca, 308 F.2d 474, 477 (5th Cir. 1962) (observing that "determination of fraudulent joinder is to be based on whether there was a real intention on col
ation of Independence, which continues to tour. Mr. Lear is married to Lyn Davis Lear and resides in Los Angeles, California. He has six children: Ellen, Kate, Maggie, Benjamin, Brianna, Madeline and four grandchildren: Daniel, Noah, Griffin, Zoe. EFTA00315150 YO-Y0 MA Yo-Yo Ma's multi-faceted ca
be effective in opening the blood-brain barrier. In 2009 Black published his autobiography, co- authored with Arnold Mann, entitled Brain Surgeon. New York Times reviewer Abigail Zuger described the book as a "fascinating, if somewhat stilted, memoir". The Publishers Weekly review commented that the book "ex
e's Hidden Dimensions and Knocking on Heaven's Door: How Physics and Scientific Thinking Illuminate the Universe and the Modern World were both on The New York Times' list of 3.00 Notable Books of the Year. Higgs Discovery: The Power of Empry Space was released as a Kindle Single in the summer of 2012 as an upda
. See, es "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay " C.M.A. v. Epstein, Case No.
he Court inspect the documents in camera in order to assess whether, in fact, continued closure is proper. See, es "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay " C.M.A. v. Epstein, Case No. 08-80811 (S.D. Fla. July 25, 2008) (filed publicly Jan. 7, 2009). 09112/2019 4 CONFIal5ENTIAL Agen
o Agency Requet: 19-411 SDNY_GM_00331875 EFTA_0020460 EFTA02729586 06-01-'09 15:32 FROM-THOMAS 8. LOCICERO 8139843070 T-987 P006/007 F-845 of the New York Times Co. v. Holtzendorf 507 So. 2d 667, 668 (Fla. 2d DCA 1987) ("While a judge may impose whatever legal sentence he chooses, if such sentence is based on a
ourt inspect the documents in camera in order to assess whether, in fact, continued closure is proper. 3 See. e.a.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v Epstein, Case No. 08-80811 (S.D. Fla. July 25, 2008) (filed publicly Jan. 7, 2009). 09/1212019 t~ge 3909 CONFIDENTIAL
See. e.a.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v Epstein, Case No. 0
o. 08-80736 (S.D. Fla. 2008). 09/12/2019 49.39.8 CONFIDENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331930 EFTA_00204656 EFTA02729640 of the New York Times Co. v. Holtzendorf, 507 So. 2d 667, 668 (Fla. 2d DCA 1987) ("While a judge may impose whatever legal sentence he chooses, if such sentence is based on a
ourt inspect the documents in camera in order to assess whether, in fact, continued closure is proper. 3 See, e.g.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v. Epstein, Case No. 08-80811 (S.D. Fla. July 25, 2008) (filed publicly Jan. 7, 2009). 09/12/2079 CONFIDENTIAL Agency to
See, e.g.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v. Epstein, Case No.
se No. 08-80736 (S.D. Fla. 2008). 09/12/2019 Plan CONF NTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331941 EFTA_002 04667 EFTA02729651 of the New York Times Co. v. Holtzendorf, 507 So. 2d 667, 668 (Fla. 2d DCA 1987) ("While a judge may impose whatever legal sentence he chooses, if such sentence is based on a
ho have made =resentations at Reality Club meetings and the more recent EDGE Seminars =nclude a wide range of people in the arts and sciences: actor Ellen =urstyn; philosopher Daniel C. 0ennett; scientists Richard Dawkins, =reeman Dyson, Niles Eldredge, Murray Gell-Mann, Stephen Jay Gould, =tewart Kau
. 001.S.WwWw...4. 00~M~~4 , WWOWNYM Visit edge.org ("Take a look. No matter who you are, you are bound to =ind something that will drive you crazy." -NEW YORK TIMES) <?xml version=.0" encoding=TF-8"?> <!DOCTYPE plist PUBLIC "-//Apple//DTD PLIST 1.0//EN" "http://www.apple.com/DTDs/Propertylist-1.0.dtd"> <plist
levant and harassing questions Plaintiff posed to her concerning her adult, consensual sexual activities. In other words, depositions of Marcincova, Kellen and Epstein would serve Plaintiff's goal to make a convoluted legal argument, not to actually seek discoverable information. In light of this, the
, and it is an absolute defense? Further, if Plaintiff cannot prove actual malice by Ms. Maxwell, her claim fails. See Contemporary Mission, Inc. v. New York Times Co., 842 F.2d 612, 621 (2d Cir. 1988) (limited purpose public figure must establish by clear and convincing evidence that the defendant published the a
y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section
¶ 29-34). These allegations, however, do not support these claims, or any other theory of liability that would allow recovery against Cf. Parks v. The New York Times Co., 308 F.2d 474, 477 (5th Cir. 1962) (observing that "determination of fraudulent joinder is to be based on whether there was a real intention on col
y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section
29-34). These allegations, however, do not support these claims, or any other theory of liability that would allow recovery against . Cf. Parks v. The New York Times Co., 308 F.2d 474, 477 (5th Cir. 1962) (observing that "determination of fraudulent joinder is to be based on whether there was a real intention on col
Entities connected to both Sarah Kellen and The New York Times

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Lesley Groff
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Marc Rich
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Alan Dershowitz
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Paul Cassell
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Virginia Giuffre
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