7
Shared Docs
5
Same-Page
16 / 9
Mentions
osition testimony in connection with third Watergate grand jury); In re Unseal Dockets Related to the Indep. Counsel’s 1998 Investigation ofPresident Clinton, 308 F. Supp. 3d 314 (D.D.C. 2018) (release of records related to independent counsel’s investigation of President Clinton); In Re: Application of th
related to independent counsel’s investigation of President Clinton); In Re: Application of the Committee on the Judi
ndment right to report information informing the public about the operation of the criminal justice system. See Va. Pharmacy Bd., 425 U.S. at 756-57; Pittman, 267 F.3d at 1283; Richmond Newspapers, 448 U.S. at 596 (“the 5 No-knock warrants have been banned in Florida since 1994. See Slate y. Bamber, 630 So
(“Where a speaker exists . . . the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both.”), Pittman v. Cole, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) (“The Supreme Court has recognized that the First Amendment offers protection to both speakers and
rm sexual fayprs. Epstein Was different from most sexual abuse suspects; he was far more powerful. He counted among his friends former President Bill.Clinton, Donald Truinp and Prince Andrew, along with some of the most prominent legal, scientific and business minds in the country. When detectives started
ys say. Unusual is the Word that best describes everything about the case against Epstein, 54, an enigmatic money manager in New York City who counts Bill Clinton and Donald: Trump among his friends. , CA/Aronbera-000173 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3 27 2023 2:57:43 PM NOT A CERTIFIED C
t. He reportedly hobnobs with the likes of former President Clinton, former Harvard University President Lawrence Sum
(“Where a speaker exists . . . the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both.”); Pittman v. Cole, 267 F.3d 1269, 1283 n. 12 (11th Cir. 2001) (“The Supreme Court has recognized that the First Amendment offers protection to both speakers an
form sexual favors. Epstein was different from most sexual abuse suspects; he was far more powerful. He counted among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along with some of the most prominent legal, scientific and business minds in the country. When detectives started
tensely private." The media frenzy did not begin in full until a decade later. In September 2002, Epstein was flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to Africa on his private jet. Suddenly everyone wanted to know who Epstein was. New York magazine and Vani
. He reportedly hobnobs with the likes of former President Clinton, former Harvard University President Lawrence Su
“Where a speaker exists . . . the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both.”); Pittman v. Cole, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) (“The Supreme Court has recognized that the First Amendment offers protection to both speakers a
form ,sexual fayors. Epstein was diff~rentfrom m:ostsexual abuse suspects; he was.far more powerfoL He cotuited among his friends former President Bill Clinton, Donald Trump and Prince,.Andrew, along with some of the most·proipinen~ leg:µ, ~cientific aJld busµi,ess minds in i,he q:rnnJry. When d~tec.tives
ntensely private.” The media.frenzy did not begin iri full until a decade later. In September 2002, Epstein was flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to Africa on his private jet. I Suddenly everyone wanted to know who Epstein was. New York magazine and Vani
) (“Where a speaker exists ... the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both.”); Pittman v. Cole, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) (“The Supreme Court has recognized that the First Amendment offers protection to both speakers and
t organizations by the United States government. See Bohn II, 291 F.3d at 1002 (noting Hamas was designated a terrorist organization by President Clinton in 1995 and by the Sec- retary of State in 1997); see also Consoli- dated Plaintiffs Opp. to Prince Sultan's Motion to Dismiss at 16-17 (citing Pate
amas was designated a terrorist organization by President Clinton in 1995 and by the Sec- retary of State in 1997);
proceed with this claim. Wantartabe Realty Corp. v. City of New York 01 Civ. 10137(LAK), 2003 WL 22862646, at *4 (S.D.N.Y. Dec. 3., 2003) (citing Pittman, 149 F.3d at 122-23). 8. Negligence 186-881 In New York, a plaintiff may establish negligent infliction of emotional distress under the bystander
- tious under New York law. Robinson, 269 F.3d at 142. In New York, conspiracy and aiding and abetting are varieties of con- certed action liability. Pittman v. Gray- son, 149 F.8d 111, 122 (@d Cir.1998). There must be “(1) an express or tacit agreement to ‘participate in a common plan or design to commit
Page: HOUSE_OVERSIGHT_017862 →rorist organizations by the United States government. See Bown I, 291 F.3d at 1002 (noting Hamas was designated a terrorist organization by President Clinton in 1995 and by the Sec- retary of State in 1997); see also Consoli- dated Plaintiffs’ Opp. to Prince Sultan’s Motion to Dismiss at 16-17 (citing Flat
Page: HOUSE_OVERSIGHT_017865 →Hamas was designated a terrorist organization by President Clinton in 1995 and by the Sec- retary of State in 1997);
Page: HOUSE_OVERSIGHT_017865 →may proceed with this claim. Wantanabe Realty Corp. v. City of New York, 01 Civ. 10187(LAK), 2003 WL 22862646, at *4 (S.D.N-Y. Dec. 3., 2003) (citing Pittman, 149 F.3d at 122-28). 8. Negligence [86-88] In New York, a plaintiff may establish negligent infliction of emotional distress under the bystander o
Page: HOUSE_OVERSIGHT_017895 →e for acting in concert with the primary tortfeasor under either theory, the defendant must know the wrongful nature of the primary actor’s conduct. Pittman v. Grayson, 149 F.3d 111, 122—23 (2d Cir.1998). Accordingly, to survive these Rule 12(b)(1) motions to dismiss, Plaintiffs must plead facts from whic
Page: HOUSE_OVERSIGHT_017919 →TRO was allegedly involved with bombings in Jordan in 1993 and 1994, the 1993 attack on the World Trade Center, plots to assassinate former President Bill Clinton and the late Pope John Paul II and to simultaneously blow up twelve American airliners, and the 1998 Embassy bombings in Africa. (Ashton Compl. Jf 31
Page: HOUSE_OVERSIGHT_017924 →enter, plots to assassinate former President Bill Clinton and the late Pope John Paul II and to simultaneou
Page: HOUSE_OVERSIGHT_017924 →Entities connected to both Bill Clinton and Yogananda Pittman

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Hillary Clinton
PERSON
Barack Obama
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONLeon Black
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Joe Biden
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
John F. Kennedy
PERSON
Les Wexner
PERSON
Prince Charles
PERSON