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but also waived his right to contest jurisdiction so long as the claims were being brought pursuant to § 2255. Only when he was placed on notice by the United States Attorney's Office that "there has been a breach in the filing (of the motion to dismiss)... And we are providing notice to Mr. Epstein today," did D
s motion contesting liability. See Transcript of Hearing before The Honorable Kenneth Marra, dated June 17, 2009, excerpts of which are attached to this Response as Exhibit 2. And, finally, this pattern of delay and non-performance is evident by his actions in this case. Despite months and months of refusing to pay Plain
but also waived his right to contest jurisdiction so long as the claims were being brought pursuant to § 2255. Only when he was placed on notice by the United States Attorney's Office that "there has been a breach in the filing (of the motion to dismiss)... And we are providing notice to Mr. Epstein today," did D
s motion contesting liability. See Transcript of Hearing before The Honorable Kenneth Marra, dated June 17, 2009, excerpts of which are attached to this Response as Exhibit 2. And, finally, this pattern of delay and non-performance is evident by his actions in this case. Despite months and months of refusing to pay Plain
but also waived his right to contest jurisdiction so long as the claims were being brought pursuant to § 2255. Only when he was placed on notice by the United States Attorney's Office that "there has been a breach in the filing (of the motion to dismiss]... And we are providing notice to Mr. Epstein today," did D
s motion contesting liability. See Transcript of Hearing before The Honorable Kenneth Marra, dated June 17, 2009, excerpts of which are attached to this Response as Exhibit 2. And, finally, this pattern of delay and non-performance is evident by his actions in this case. Despite months and months of refusing to pay Plain
Entities connected to both United States and this Response as Exhibit 2

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Virginia Giuffre
PERSONSouthern District
LOCATIONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
the United States District Court
ORGANIZATION
Barry Diller
PERSON
Ken Starr
PERSONRobert C. Josefsberg
PERSON
Jeffrey Sloman
PERSONScott Rothstein
PERSON
Podhurst
PERSON