Epstein Secrets

confidential information governed by the protective order to other government agencies for the purpose of enforcing the criminal or civil laws of the United States. Thus, the Government seeks to reserve the right to use confidential information produced by Fisher in this case in unrelated civil or criminal ma

ce of parties and witnesses and in interest of justice bears burden of estab- lishing by preponderance of evidence that transfer is necessary. 28 U.S.C.A. § 1404(a). 6. Federal Courts 6=101, 103, 105 Although trial judge is afforded great discretion in deciding motion to transfer for convenience of

n, Diane Fisher, Fisher & Soffer, a l D. Gerzog, Robert Heilbrun, Suzanne McDermott, Christopher . artm, Jessie Siegel, Siegel, Martin, Ron Soifer, Carmen Talsig, John Does 1 - 10, X Corporations 1-10; Summons issued. (sac) (Entered: 12/30/1997) 01/05/1998 29 Filed Memo-Endorsement on letter dated 12/30/97

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

ence D. Gerzog, Robert Heilbrun, Suzanne McDermott, Christopher H. Martin, Jessie Siegel a/k/a Jesse Siegel, Siegel, Martin & Heilbrun, Ron Soifer, Carmen Talsig, John Does 1 through 10 and X Corporations 1 through 10 as defendants (collectively, "Fisher's subtenants"). By stipulation and order signed by this

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

ir, D. Gerzog, Robert Heilbrun, Suzanne McDermott, Christopher H. Martin, Jessie Siegel a/k/a Jesse Siegel, Siegel, Martin & Heilbrun, Ron Soffer, Carmen Talsig, John Does 1 through 10 and X Corporations 1 through 10 as defendants (collectively, "Fisher's subtenants"). By stipulation and order signed by this

4311(a). 24. The Secretary of State (the "Secretary") is empowered under the FMA to determine the treatment to be accorded to a foreign mission in the United States. Id. § 4301(c); see § 4302(a)(6). The FMA provides that "a denial by the Secretary involving a benefit of a foreign mission within the jurisdiction

ence D. Gerzog, Robert Heilbrun, Suzanne McDermott, Christopher H. Martin, Jessie Siegel a/k/a Jesse Siegel, Siegel, Martin & Heilbrun, Ron Soffer, Carmen Talsig, John Does 1 through 10 and X Corporations 1 through 10 (collectively, the "Defendants") in connection with certain premises located at 34 East 69t

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

ence D. Gerzog, Robert Heilbrun, Suzanne McDermott, Christopher H. Martin, Jessie Siegel a/k/a Jesse Siegel, Siegel, Martin & Heilbrun, Ron Soffer, Carmen Talsig, John Does 1 through 10 and X Corporations 1 through 10 as defendants (collectively, "Fishers subtenants"). By stipulation and order signed by this