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those individuals. Part of that involves a personality I'm sure your Honor is familiar with, Mr. Jeffrey Epstein ... Mr. Epstein, I'm told, and Mr. Kramer may want to address this in more specifics, but Mr. Epstein is a critical player here. ... and he's [Epstein] not a victim." (Moskowitz Decl. at Ex.
tements were made; and (4) explain why the statements were fraudulent. Anatian v. Coutts Bank (Swift) Ltd., 193 F.3d 85, 88 (2d Cir. 1999) (quoting Shields v. Citytrust Bancorp, Inc., 25 F.3d 1124, 1128 (2d Cir. 1994)). Plaintiffs' Complaint fails miserably to meet this standard. Under Rule 9(b), Plaint
during the outgoing Trump Administration." While the New York Times <https://www.nytimes.corn/2020/11/24/world/sputnik-vaccine-russia.html> (11124, Kramer, 18.61M) reports the manufacturers of the "leading Russian vaccine candidate" Sputnik V "said on Tuesday that it showed an efficacy rate of 95 perce
Bloomberg <https://www.bloomberg.com/news/articles/2020-11-24/zte-corp-s-designation-as-security-threat- affirmed-by-u-s-fcc?smd=politics-vp> (11/24, Shields, 4.73M) reports that the FCC "affirmed its decision to designate ZTE Corp. as a national security threat over concerns telecommunications gear made
unties. Intelligence Officials: Russia's Grievances Against American Interference May Explain Bounty Allegations. The New York Times (7/3, Higgins, Kramer, 18.61M) reports, "Russian officials and commentators reacted with fury" to the news that "American intelligence officials had concluded that Russi
novel coronavirus that has killed more than half a million people." Meanwhile, WHO Chief Scientist Soumya Swaminathan told Reuters (7/3, Nebehay, Shields) on Friday that nearly 30% of the genome sequencing data from the WHO's samples of the virus "have shown signs of mutation, but there is no evidence
y the rise of authoritarian powers and the retreat of the United States during the outgoing Trump Administration." While the New York Times (11/24, Kramer, 18.61M) reports the manufacturers of the "leading Russian vaccine candidate" Sputnik V "said on Tuesday that it showed an efficacy rate of 95 perc
agents seized her electronic devices and secured passcodes." FCC Affirms Decision To Designate ZTE As National Security Threat. Bloomberg (11/24, Shields, 4.73M) reports that the FCC "affirmed its decision to designate ZTE Corp. as a national security threat over concerns telecommunications gear made
Entities connected to both Kramer and Shields

Jeffrey Epstein
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Donald Trump
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Julie K. Brown
PERSONLeon Black
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Michigan
LOCATION
Samantha Power
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Stephen Hawking
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Supreme Court
ORGANIZATION
Department of Justice
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George W. Bush
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George Mitchell
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Wilbur Ross
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Robert Gates
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United Kingdom
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Virginia Giuffre
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Condoleezza Rice
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United States
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Abraham Lincoln
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Alaska
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Prince Andrew
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