Epstein Secrets

IV-MARRAMOHNSON EFTA00208068 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 33 of 54 The district court found that the United States' admission that Dr. Jackson was an employee was not a judicial admission, because "[w]hether Dr. Jackson was a federal employee under the FTCA appea

. 2005) (emphasis added). In W.R. me, petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the Rigas family. Two members of the Rigas family were convicted of securities fraud. A third was acquitted. Adelphia Communications

te "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. v. Metropolitan Dade County, 932 F.2d 1239, 1243 (11ih Cir. 1991)(citations omitted). 8 Respondent's Exhibit A Case No. 08-80736-CIV-MARRAM

tes. Id. at *5. 32 EFTA00078866 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 33 of 54 The district court found that the United States' admission that Dr. Jackson was an employee was not a judicial admission, because "[w]hether Dr. Jackson was a federal employee under the FTCA appea

. 2005) (emphasis added). In W.R. me, petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the Rigas family. Two members of the Rigas family were convicted of securities fraud. A third was acquitted. Adelphia Communications

te "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. v. Metropolitan Dade County, 932 F.2d 1239, 1243 (11ih Cir. 1991)(citations omitted). 8 EFTA00078842 Case 9:08-cv-80736-KAM Document 62 En

FILED by /g..3 D.C. JUL 0 9 2008 STEVEN M. LARDAORE CLERK U.S. DIST. CT. S.D. Of FLA. • wee. DECLARATION OF A. MARIE VILLAFARA IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT QF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771 I. I, A. Marie Villafafia, do hereby declare

se the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing to discuss petitioners' request for a copy of the non-pros

diction of the trial court, or, is capable of accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned. Cash Inn of Dade. Inc.'. Metropolitan Dade County, 938 F.2d 1239, 1243 (11th Cir. 1991)("A district court may take judicial notice of public records within its files

n to support petitioners' claims against Jeffrey Epstein for money damages, particularly with regard to obtaining documents and information from the United States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no EFTA00206726 need for this auxiliary litigation

E "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. I Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may p

n to support petitioners' claims against Jeffrey Epstein for money damages, particularly with regard to obtaining documents and information from the United States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no EFTA00206823 need for this auxiliary litigation

E "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. v. Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may

n to support petitioners' claims against Jeffrey Epstein for money damages, particularly with regard to obtaining documents and information from the United States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no EFTA00206756 need for this auxiliary litigation

E "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. I Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may p

n to support petitioners' claims against Jeffrey Epstein for money damages, particularly with regard to obtaining documents and information from the United States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no EFTA00235793 need for this auxiliary litigation

2. "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. I Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may p