Epstein Secrets

is raising, the Court must "take the factual allegations in the complaint as true and construe them in the light most favorable to the plaintiffs." Edwards v. Prime, Inc., 602 F.3d 1276, 1291 (11ih Cir. 2010). In the current posture of this case, the victims have pending a motion for "summary judgment"

ity to review this case. CONCLUSION The Court should deny the Government's motion to dismiss. DATED: December 5, 2011 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 Te

dhurst, N.J. v. Priceline.com Inc., 657 F.3d 148, 155 (r d Cir. 2011) (request for equitable relief creates standing); Amnesty International USA v. Clapper, 638 F.3d 118, 140 (2d Cir. 2011) (request for injunction sufficient to confer standing to proceed). And on top of all that, these remedies also pr

bought a two-story house in Croften, Maryland, a residential community very close to the NSA’s headquarters building at Fort Meade. The two children, Edward, who was nine, and Jessica, who was 12, were enrolled in local public schools in Croften. Jessica was a top student. She graduated high school, comp

Intelligence Committee on March 12, 2013. Senator Ron Wyden (D-Oregon) of the Committee asked the spy master if the NSA collected data on Americans. Clapper answered that the NSA did not knowingly “collect any type of data” on millions of Americans. Clapper’s answer was clearly untrue. However, it did not

ier that the NSA did not collect phone data in America. This warrant would allow the Guardian, in the best tradition of “Gotcha” journalism, to catch Clapper in an apparent lie. Continuing his string-pulling, he instructed Poitras not to show the FISA warrant to Greenwald until they were safely aboard the

appropriate equitable remedy."). And the CVRA is obviously "remedial legislation" that should be broadly construed to achieve its remedial purposes. Edwards. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008). A good illustration of the broad power of district courts to remedy CVRA violation

ity to review this case. CONCLUSION The Court should deny the Government's motion to dismiss. DATED: December 5, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, UT \Ill A Tile UTOTAO 0. T M.TDIN A XT Tip T and Paul G. Cassell Pro Hac Vice Attorneys for Ja

Lyndhurst, N.J. I Priceline.com Inc., 657 F.3d 148, 155 (3nd Cir. 2011) (request for equitable relief creates standing); Amnesty International USAl Clapper, 638 F.3d 118, 140 (2d Cir. 2011) (request for injunction sufficient to confer standing to proceed). And on top of all that, these remedies also pr

ore in 1992, he bought a two-story house in Crofton, Maryland, a resi- dential community very close to the NSA’s headquarters building at Fort Meade. Edward, who was nine, and Jessica, who was twelve, were enrolled in local public schools in Crofton. Jessica was a top student. After she obtained her degr

ing records for ninety days to the NSA. It was as close to a smoking gun as anything he had copied at the NSA. It would also get atten- tion because James Clapper, the director of national intelligence, had stated before Congress just two months earlier that the NSA did not collect phone data in America. This w

ier that the NSA did not collect phone data in America. This warrant would allow The Guard- ian, in the best tradition of gotcha journalism, to catch Clapper in an apparent lie. Continuing his string pulling, Snowden instructed Poitras not to show the FISA warrant to Greenwald until they were safely aboar

row, Joseph. Fact and Fable in Psychology. Boston: Houghton, Mifflin, 1900. Kahn, David. The Codebreakers. New York: Simon & Schuster, 1967. Lucas, Edward. The Snowden Operation. Seattle: Amazon Digital Services, 2015. Morell, Michael J. The Great War of Our Time. New York: Twelve, 2015. Sebag-Montefi

vey Oswald (New York: McGraw-Hill, 1978), 64-104. 129 Clapper answered that: The transcript was published by The Washington Post, Jan. 29, 2014. For Clapper’s earlier closed-door testimony, see Steven Aftergood, “The Clapper ‘Lie’ and the Senate Intelligence Committee,” FAS, Jan. 6, 2014. 130 On his appl

vernment, and defected to Russia. See Edward Jay Epstein, Legend: The Secret World of Lee Har- vey Oswald (New York: McGraw-Hill, 1978), 64-104. 129 Clapper answered that: The transcript was published by The Washington Post, Jan. 29, 2014. For Clapper’s earlier closed-door testimony, see Steven Aftergood,

277—78 White House appointments and, 4, 36, 86-87, 89, 189, 285 Barra, Mary, 88 Barrack, Tom, 27-29, 33, 42, 85, 233, 240 Bartiromo, Maria, 205 Bass, Edward, 56 Bayrock Group, 100-102 Bedminster Golf Club, 165, 213-14, 216, 287-94, 297, 302, 307 Beinart, Peter, 297 Benghazi, 97 Berkowitz, Avi, 143 Berlusc

9-70, 297 Chopra, Deepak, 80 Christie, Chris, 16, 24-25, 30-31, 210, 242, 279 Christoff, Niki, 78 Churchill, Winston, 50 Circa news website, 159, 257 Clapper, James, 41, 214-15 Clinton, Bill, 23, 27, 54, 58, 90, 116, 123, 128, 158, 225, 228 impeachment of, 201, 233, 280 Clinton, Hillary, 3, 11-12, 18, 35,