Epstein Secrets

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

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 McDermott, Christopher H. Martin, Jesse Siegel a/k/a Jessie Siegel, Siegel, Martin & Heilbrun, Ron Soffer, and Carmen Taus

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

/ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl7321462322339233-L 353_0-1 5/22/2007 EFTA00187446 SDNY CM/ECF Version 3.0L - Docket Report Page 3 of 14 Gerzog Defendant Robert Heilbrun Defendant Suzanne McDermott Defendant Christopher H. Martin Defendant Jessie Siegel also known as Jesse Siegel D

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

emises; has availed itself of the use and benefits of the Premises; and has or may claim to have an interest in the Premises. Lawrence D. Gerzog ("Gerzog") is a resident of the State of New York with a business address at 34 East 69th Street, New York, New York. Gerzog is named as a defendant because

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

the Premises; has availed itself of the use and benefits of the Premises; and has or may claim to have an interest in the Premises. 8. D. Gerzog ("Gerzog") is a resident of the State of New York with a business address at 34 East 69th Street, New York, New York. Gerzog is named as a defendant because

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

s; has availed itself of the use and benefits of the Premises; and has or may claim to have an interest in the Premises. 11. Lawrence D. Gerzog ("Gerzog") is a resident of the State of New SONY_GM_02742768 EFTA _00229417 EFTA01324983 York with a business address at 34 East 69th Street, New York,