Epstein Secrets

lburn LLP, Omar T. Mohammedi, Law Office of Omar T. Mohammedi, Brian Howard Polovoy, Shearman & Sterling LLP (New York), Geoffrey S. Stewart, Michael Bradley, Jones Day, Matthew Phineas Previn, Wilmer, Cutler & Pickering, L.L.P., T. Barry Kingham, Curtis, Mallet-Prevost, Colt and Mosle LLP, New York City,

estments, Mar-Jac Poultry, Reston Investments, Safa Trust, and York Foundation, move to dismiss the Burnett complaint. IIIT also moves to dismiss the Ashton complaint. In addition to its motion to dismiss Burnett, Mar—-Jac Poultry moves to dismiss the Ashton and Federal complaints. The Federal Plaintiffs

ry actions, even when that discretion is abused). Accordingly, the Court finds SHC is immune from suit in this litigation. Its motions to dismiss the Ashton, Burnett, and Federal complaints for lack subject matter jurisdiction are granted. 2. Prince Salman and Prince Naif M11 Similarly, even if Plaintiff

helpful in assessing whether any of Rabita Trust’s activities were directed at the United States. Accordingly, Rabita Trust’s motions to dismiss the Ashton, Burnett, and Federal complaints are denied without prejudice. C. Wa‘el Jalaidan® 21 The United States Department of Treasury has designated Defenda

y to which requests, the Government should be required to provide such a responsive document. DATED: October 28, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 an

such a responsive document. DATED: October 28, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College

cted? The declaration from Robin C. Ashton, Counsel of OPR, only deepens the mysteries swirling around the Government's privilege log. For example, Ashton asserts "deliberative process" privilege over allegedly internal communications that were designed to "finalize" a letter that was to be sent to U.

SERVICE LIST Jane Does 1 and 2'. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale FL 33301-3268 Paul G. Cassell S.J. Quinney College o

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

d with attorney notes on telephone call and Howard with Suppl. Box 3 P-013948 Thru P-013951 E-mail, to Howard and Robin C. any work-product Ashton, May 3, 2011, 12:30 p.m., FW: OPR Inquiry — request for information, with attached e-mails. Handwritten attorney notes on margin Page 13 of 14 EF

occurs in the United States." Burnett II, 292 F.Supp2d at 19 n. 4 (quoting Tel-Oven v. Libyan Arab Republic, 726 F.24 774, 775 (D.C.Cir.1984)) (Edwards, J., concurring) (some emphasis omitted). Courts in the Second Circuit seem to take the opposite approach. "Although cast in terms that may be re

ng con- clusion of jurisdictional discovery on that issue. In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001 Burnett v. Al Baraka Inv. & Der. Corp. Ashton v. Al Qaeda Islamic Army Tremsky v. Qsama Bin Laden Salvo v. Al Qaeda Islamic Army Burnett v. Al Baraka Inv. & Der. Corp. Federal In- surance v. A