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ners argue that the Court should accept their Statement as true, despite its conclusory allegations and internal inconsistencies, solely because of the United States' failure to stipulate to the Statement. The Court should deny the motion because: (1) Petitioners have misstated that United States' efforts at reach
to "completely and permanently obliterate and strike from the records of the pleas of guilty . . . any and all identifying reference to or name of Mt Smith, the Petitioner, so that such references may not be used as a public record to impugn the reputation of Petitioner." Id. at 1107. The Court further
re well aware that they received notifications of Epstein's work release status. EFTA00208507 CONCLUSION For the reasons set forth herein and in the United States' Response to Jane Does #1 and #2's Motion for Finding of Violations of the Crime Victims Rights Act and Request for a Hearing on Appropriate Remedies
to "completely and permanently obliterate and strike from the records of the pleas of guilty . . . any and all identifying reference to or name of Mt Smith, the Petitioner, so that such references may not be used as a public record to impugn the reputation of Petitioner." Id. at 1107. The Court further
re well aware that they received notifications of Epstein's work release status. EFTA00212557 CONCLUSION For the reasons set forth herein and in the United States' Response to Jane Does #1 and #2's Motion for Finding of Violations of the Crime Victims Rights Act and Request for a Hearing on Appropriate Remedies
to "completely and permanently obliterate and strike from the records of the pleas of guilty . . . any and all identifying reference to or name of Mt Smith, the Petitioner, so that such references may not be used as a public record to impugn the reputation of Petitioner." Id. at 1107. The Court further
Entities connected to both United States and Mt Smith

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
Southern District of New York
ORGANIZATION
Paul Cassell
PERSON
Barry Diller
PERSON
West Palm Beach
LOCATION
Puerto Rico
LOCATION
Anderson
PERSONthe Eleventh Circuit
ORGANIZATIONRubin
PERSON
North
LOCATIONJames Eisenberg
PERSON
the Fifth Circuit
ORGANIZATIONthe Court of Appeals
ORGANIZATIONAguirre-Gonzalez
PERSONDow Jones & Co.
ORGANIZATIONthe District Court Clerk's Office
ORGANIZATION