Epstein Secrets

nvolved use of means of interstate commerce (i.e., a telephone) and travel in interstate commerce. Both Jane Does were initially identified through the Palm Beach Police Department's investigation of Epstein. 76. Confirming the fact that the Government had identified Jane Doe No. 1 as a victim in this case, on about June 7, 200

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). EFTA00208647 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 41 of 64 On September 26, 2011, the Court den

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Co

nvolved use of means of interstate commerce (i.e., a telephone) and travel in interstate commerce. Both Jane Does were initially identified through the Palm Beach Police Department's investigation of Epstein. 76. Confirming the fact that the Government had identified Jane Doe No. 1 as a victim in this case, on about June 7, 200

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). EFTA00081155 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 41 of 64 On September 26, 2011, the Court den

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Co

nvolved use of means of interstate commerce (i.e., a telephone) and travel in interstate commerce. Both Jane Does were initially identified through the Palm Beach Police Department's investigation of Epstein. 76. Confirming the fact that the Government had identified Jane Doe No. 1 as a victim in this case, on about June 7, 200

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). EFTA00179738 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 41 of 64 On September 26, 2011, the Court den

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Co

correct. The government admits that AUSA received from attorneys, and turned over to AUSA and others in the office, including flight records and Palm Beach Police Department Records. Resp. at 66 & n.2. Both of these documents were produced in discovery in the civil case. 9 EFTA00077584 From any perspective, therefore, AUSA

0077571 Table of Contents Table of Contents Table of Authorities ii Table of Exhibits iv Introduction and Summary of the Argument 1 I. The Facts 2 II. The Government's Response to Maxwell's Motion. 6 A. The Government's Defenses Are Not Credible. 7 B. Assuming the Government's Defense