Epstein Secrets

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

tacts book contains a work and a home telephone number for the senator. air New York reality , hi Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail anew on Sunday: ‘Mr Barak did attend several small functions in Mr Epstein’s home in New York that were vers ’bana?

senator. air New York reality , hi Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail anew on Sunday: ‘Mr Barak did attend several small functions in Mr Epstein’s home in New York that were vers ’bana? usually attended by leading businessman, university presid

rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

that the crime be Iserved as U. S. Attorney for the Southern District of Florida em an interstate nexus. Secoi e . : |

er, Dustin Hoff- : F man, Ralph Fiennes, David Koch, Ted Kennedy, Donald Trump, | j Bill Richardson, Bill Clinton, and former Israeli prime minister 4 Ehud Barak among them. S) 4 This was intriguing, if not at all damning. Epstein made a i E habit of collecting such information for future use. But informa- 4

Clinton, and former Israeli prime minister 4 Ehud Barak among them. S) 4 This was intriguing, if not at a

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

rince Andrew Epstein’s contacts book contains a work and a home telephone number for the senator. Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail on Sunday: ‘Mr Barak did attend several small functions in Mr Epstein’s home in New York that were usually attended by

d a home telephone number for the senator. Another acquaintance was Israel defence secretary Ehud Barak, whose spokesman told The Mail on Sunday: ‘Mr Barak did attend several small functions in Mr Epstein’s home in New York that were usually attended by leading businessman, university presidents, Nobel P

a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein,

e. But the question remains: Did Epstein’s wealth and social connections—former President Bill Clinton; Prince Andrew; former Israeli Prime Minister Ehud Barak; New Mexico Gov. Bill Richardson; and former Treasury Secretary Larry Summers were just a few of the prominent passengers on his private jets—allow h

Prince Andrew; former Israeli Prime Minister Ehud Barak; New Mexico Gov. Bill Richardson; and former Trea

r claims against these financial sponsors of terrorism. Statement Of Subject Matter and Appellate Jurisdiction The United States District Court for the Southern District of New York had subject matter jurisdiction over these actions pursuant to 28 U.S.C. § 1330, 1331, 1332, 1350, 1367, 1407, and 1605, 18 U.S.C. §§ 1964 and 2338,

rorist activities and to be affiliated with al-Qaeda. See Wyatt, 785 F. Supp. 2d at 647-48; see also Goldberg v. UBS AG, 660 F. Supp. 2d 410, 428-29 (E.D.N.Y. 2009) (finding that plaintiffs had “sufficiently pled that the defendant consciously disregarded the fact that it was supporting a terrorist organiza

subsidiaries. JA1782, 3122, 3832. C. The District Court Incorrectly Disregarded Extensive Allegations of Support to al-Qaeda by Defendants Dallah al Baraka and Saleh Abdullah Kamel in the Early to Mid 1990s The district court also found that the plaintiffs had not pled “the requisite causal connection”