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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
such, they were recognized as consular property by the United States Department of State ("State Department"), Office of Foreign Missions ("OFM") (Massey Dec., Exh. A thereto), and enjoyed the protection of the Foreign Missions Act ("FMA"), ss& 22 U.S.C. §§ 4302(a)(3)-(4), the Vienna Convention on Consular Rela
U.S.C. § 1701 et seq . ("IEEPA"), authorities thereunder and a license granted to OFM by the Treasury Department, Office of Foreign Assets Control (Massey Dec., Exh. B thereto). OFM is empowered to bring this action to seek equitable relief to protect the premises, see 22 U.S.C. §§ 4301(b)-(c), 4311(a), and to c
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
such, they were recognized as consular property by the United States Department of State ("State Department"), Office of Foreign Missions ("OFM") (Massey Dec., Exh. A thereto), and enjoyed the protection of the Foreign Missions Act ("FMA"), ss& 22 U.S.C. §§ 4302(a)(3)-(4), the Vienna Convention on Consular Rela
U.S.C. § 1701 el seq . ("IEEPA"), authorities thereunder and a license granted to OFM by the Treasury Department, Office of Foreign Assets Control (Massey Dec., Exh. B thereto). OFM is empowered to bring this action to seek equitable relief to protect the premises, = 22 U.S.C. §§ 4301(b)-(c), 4311(a), and to con
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
U.S.C. § 1701 et seq. ("IEEPA"), authorities thereunder and a license granted to OFM by the Treasury Department, Office of Foreign Assets Control (Massey Dec., Exh. B thereto). OFM is empowered to bring this action to seek equitable relief to protect the premises see 22 U.S.C. §§ 4301(b)-(c), 4311(a), and to c
Entities connected to both United States and Massey Dec., Exh

Jeffrey Epstein
PERSONSouthern District
LOCATION
Michael Cohen
PERSON
Lawrence Krauss
PERSON
U.S. Treasury
ORGANIZATIONFisher
PERSON
Idaho
LOCATIONGardner
PERSON
Office of Foreign Assets Control
ORGANIZATIONBurnett
PERSONMassey
LOCATIONEllyn Bank
ORGANIZATIONRon Soffer
PERSONthe International Emergency Economic Powers Act
ORGANIZATIONMartin & Heilbrun
ORGANIZATIONChristopher H. Martin
PERSONIvan S. Fisher
PERSONDebra Elisa Cohen
PERSONRobert Heilbrun
PERSONFisher & Sophir
ORGANIZATION