Epstein Secrets

Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16 Reid Weingarten 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main 212 506 3955 direct www.steoloccorn nreeinoartenOsteotoe.com July 11, 2019 VIA ECF The Honorable Richard

ed States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992). Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States. 5 Mr. Epstein owns one private jet. He sold the other jet in June 2019. 4 EFTA00076071 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 5

. Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litiga

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significant

URT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United States hereby requests that this Court enter an order dismissing these

nsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significant

URT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United States hereby requests that this Court enter an order dismissing these

nsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significantl

URT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United States hereby requests that this Court enter an order dismissing these

nsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significantl

URT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United States hereby requests that this Court enter an order dismissing these

nsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significantl

ed States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992). Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States. 5 Mr. Epstein owns one private jet. He sold the other jet in June 2019. 4 EFTA00095874 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 5

. Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litiga

or lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significant

0799528 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 36 of 101 Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Mauer Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

tution. See In re W.R. Huff, 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

a Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003). A. This Court Must Addr

0795204 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 36 of 1W. Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Mailer Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

tution. See In re W.R. Huff, 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

a Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003). A. This Court Must Addr

0081049 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 36 of 101 Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

itution. See In re W.R. Huff 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

a Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass 'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003). A. This Court Must Add

fice, an event that did not occur until June 2008. DE 48 at 1 41 & Ex. Eat 5. 34 EFTA00208856 Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Mauer Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

tution. See In re W.R. Huff, 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

a Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007); Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006); National Parks Conservation Ass'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003). A. This Court Must Addr