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special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces
sult of such violation may sue in any appropriate United States District Court and shall recover the actual damag
itled to judgment as a matter of law. Celotex v. Catrett, 477 U.S. 317, 106 S.Ct. 2548, 2552, 91 L.Ed.2d 2
ct Court, Southern District of Florida, for the period January 1, 2001 to the present. II. THERE HAS NEVER BEEN ANY "CASE" OR "COURT PROCEEDING" IN THE UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF FLORIDA, AGAINST JEFFREY EPSTEIN. A. Victim's Claims a On July 7, 2008, Jane Doe filed her Emergency Victim's
establish the existence of an element essential to the party's case, and on which the party will bear the burden of proof at trial. Celotex Corp. I Catrett , 477 U.S. 317, 321 (1986). At the summary judgment stage, the district court's task is to determine if there is no genuine issue as to any materia
p this [i.e., the NPA] from becoming public." (DE 407 at ¶ 37.) On September 24, 2007, Epstein and the Office formally reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the Office accordingly entered into a NPA reflecting su
Page: EFTA00010513 →R. Civ. P. 56(a). The stringent burden of establishing the absence of a genuine issue of material fact lies with the moving party. Celotex Corp. v. Catrett 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, In
Page: EFTA00010530 →ein was within his rights to attempt to persuade higher authorities within the Department of Justice to overrule the prosecutorial decisions of the U. S. Attorney's Office in the Southern District of Florida, the CVRA was designed to give the victims the same opportunity to attempt to affect prosecuto
Page: EFTA00010537 →p this [i.e., the NPA] from becoming public." (DE 407 at 1137.) On September 24, 2007, Epstein and the Office formally reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the Office accordingly entered into a NPA reflecting su
Page: EFTA00027672 →R. Civ. P. 56(a). The stringent burden of establishing the absence of a genuine issue of material fact lies with the moving party. Celotex Corp. v. Catrett 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, In
Page: EFTA00027689 →Entities connected to both United States and Catrett

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Jay Lefkowitz
PERSON
Martha Stewart
PERSON
the United States District Court
ORGANIZATION
Palm Beach
LOCATION
Ken Starr
PERSONScott Rothstein
PERSON
Anderson
PERSONWalker
PERSON
Barry Krischer
PERSONHerman
PERSONJack Scarola
PERSON
Jeffrey Marc Herman
PERSON