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racts, Epstein and Fisher continue, the lease between OFM and Epstein contains an implied covenant of good faith and fair dealing, citing Neal & Co. I. United States, 36 Fed. Cl. 600 (1996), affd, 121 F.3d 683 (Fed.Cir.1997). The requirement of good faith and fair dealing, they argue, prohibits OFM from withholdi
ter that federal law should apply, there is no federal statutory or common law governing landlord-tenant relations. Federal law should apply because the United States is a party. I have jurisdiction over this action based on 28 U.S.C. s 1345 and the FMA, 22 U.S.C. s 4301 et seq. The subject matter of this action i
o Orig. U.S. Govt. Works Not Reported in F.Supp. (Cite as: 1998 WL 159055 (S.D.N.Y.)) United States of America, Plaintiff, I. Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a the Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, D. Gerzog, Robert Heilbrun, Suzanne Mc
the Foreign Missions Act ("FMA"), ss& 22 U.S.C. §§ 4302(a)(3)-(4), the Vienna Convention on Consular Relations ("VCCR"), a bilateral treaty between the United States and Iran. See 21 U.S.T. 77, 596 U.N.T.S. 261, TIAS 6820, art. 27(a)(a). Following the severance of diplomatic ties between the United States and Ira
4307, and "beneficial use" thereof. See id . § 4302(a)(4). Prior Proceeding& EFTA00204755 The Government originally named Jeffrey E. Epstein and Ivan S. Fisher as defendants (the "original defendants"), seeking equitable and monetary relief against them concerning their unpermitted uses of the premises. F2
ter that federal law should apply, there is no federal statutory or common law governing landlord-tenant relations. Federal law should apply because the United States is a party. I have jurisdiction over this action based on 28 U.S.C. s 1345 and the FMA, 22 U.S.C. s 4301 et seq. The subject matter of this action i
Orig. U.S. Govt. Works Not Reported in F.Supp. (Cite as: 1998 WL 159055 (S.D.N.Y.)) United States of America, Plaintiff, v. Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a the Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, Lawrence D. Gerzog, Robert Heilbrun, Su
the Foreign Missions Act ("FMA"), ss& 22 U.S.C. §§ 4302(a)(3)-(4), the Vienna Convention on Consular Relations ("VCCR"), a bilateral treaty between the United States and Iran. See 21 U.S.T. 77, 596 U.N.T.S. 261, TIAS 6820, art. 27(a)(a). Following the severance of diplomatic ties between the United States and Ira
7, and "beneficial use" thereof. See id . § 4302(a)(4). A. Prior Proceeding& EFTA00223063 The Government originally named Jeffrey E. Epstein and Ivan S. Fisher as defendants (the "original defendants"), seeking equitable and monetary relief against them concerning their unpermitted uses of the premises. F2
e Nakano Dec. ¶ 8 & n.2; Exh. G thereto). ARGUMENT THE PRESENT RESPONDENTS SHOULD BE EJECTED FROM THE PREMISES Under the Foreign Missions Act, "[t]he United States, acting on its own SONY_GM_02742790 EFTA _00229439 EFTA01325005 behalf or on behalf of a foreign mission, has standing to bring ... an action to
known as 34 East 69th Street, New York, New York (the "premises"). On February 2, 1998, the Government requested that the subtenants of defendant Ivan S. Fisher, including Ms. Fisher and Ron Soffer, stipulate to the relief sought in this motion. Apparently, as of this writing, Ms. Fisher's counsel has not be
ter that federal law should apply, there is no federal statutory or common law governing landlord-tenant relations. Federal law should apply because the United States is a party. I have jurisdiction over this action based on 28 U.S.C. s 1345 and the FMA, 22 U.S.C. s 4301 et seq. The subject matter of this action i
Orig. U.S. Govt. Works Not Reported in F.Supp. (Cite as: 1998 WL 159055 (S.D.N.Y.)) United States of America, Plaintiff, v. Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a the Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, Lawrence D. Gerzog, Robert Heilbrun, Su
Entities connected to both United States and Ivan S. Fisher

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
New York
LOCATIONSouthern District
LOCATION
Michael Cohen
PERSON
Southern District of New York
ORGANIZATION
Stephen Hawking
PERSON
United States District Court
ORGANIZATION
Lawrence Krauss
PERSON
U.S. Treasury
ORGANIZATION
Bill Richardson
PERSON
New York State
LOCATION
Oregon
LOCATION
Anderson
PERSONFisher
PERSON
Bill Burns
PERSON
Idaho
LOCATIONGardner
PERSON
Ecuador
LOCATION