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

ilbrun 575 Madison Avenue New York, NY 10022 RR IMEY represented by Robert Heilbrun (See above for address) LEAD ATTORNEY represented by Robed Heilbrun (See above for address) LEAD ATTORNEY represented by Robert Heilbrun (See above for address) LEAD ATTORNEY represented by Steven J Cohen (See

ign policy concerns and issues of reciprocity among nations. See id . The FMA defines a "foreign mission" as "any mission to or agency or entity in the United States which is involved in the diplomatic, consular, or other activities of, or which is substantially owned or effectively controlled by ... a foreign go

e Premises. Robert Heilbrun ("Heilbrun") is a resident of the State of New York with a business address at 34 East 69th Street, New York, New York. Heilbrun is named as a defendant because he is an unapproved occupant of the Premises; has availed himself of the use and benefits of the Premises; and has o

RNATIONAL TREATIES AND STATUTORY SCHEMES A. The Foreign Missions Act of 1982 1. Pursuant to the FMA, 22 U.S.C. § 4301 et seq ., "the operation in the United States of foreign missions ... is a proper subject for the exercise of Federal jurisdiction." Id . § 4301(a). The FMA provides, inter alia , that "it is th

mises. 10. Robert Heilbrun ("Heilbrun") is a resident of the State of New York with a business address at 34 East 69th Street, New York, New York. Heilbrun is named as a defendant because he is an unapproved occupant of the Premises; has availed himself of the use and benefits of the Premises; and has

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

mises. 13. Robert Heilbrun ("Heilbrun") is a resident of the State of New York with a business address at 34 East 69th Street, New York, New York. Heilbrun is named as a defendant because he is an unapproved occupant of the Premises; has availed himself of the use and benefits of the Premises; and has