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ners argue that the Court should accept their Statement as true, despite its conclusory allegations and internal inconsistencies, solely because of the United States' failure to stipulate to the Statement. The Court should deny the motion because: (1) Petitioners have misstated that United States' efforts at reach
e `external party!" Senate of the Commonwealth of Puerto Rico I United States Dep't of Justice , 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry I United States , 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(e) does not create a type of secrecy which is waived once public disclosure occurs. The Government is
n to Use Correspondence to Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings Unsealed (DE51). As explained in the United States' Response to Petitioners' Motion for Finding of Violations of the Crime Victims Rights Act (DE48), and Petitioners' Motion to Have Their Facts Accep
`external party.'" Senate of the Commonwealth of Puerto Rico I United States Dep't of Justice , 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry I United States , 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(e) does not create a type of secrecy which is waived once public disclosure occurs. The Government is
re well aware that they received notifications of Epstein's work release status. EFTA00212557 CONCLUSION For the reasons set forth herein and in the United States' Response to Jane Does #1 and #2's Motion for Finding of Violations of the Crime Victims Rights Act and Request for a Hearing on Appropriate Remedies
e 'external party.' Senate of the Commonwealth of Puerto Rico I United States Dep ' of Justice , 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry I United States , 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(e) does not create a type of secrecy which is waived once public disclosure occurs. The Government is
Entities connected to both United States and Barry I United States

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
Southern District of New York
ORGANIZATION
Barry Diller
PERSON
West Palm Beach
LOCATION
Puerto Rico
LOCATION
Anderson
PERSONthe Eleventh Circuit
ORGANIZATIONRubin
PERSON
North
LOCATIONJames Eisenberg
PERSON
the Fifth Circuit
ORGANIZATIONthe Court of Appeals
ORGANIZATIONAguirre-Gonzalez
PERSONDow Jones & Co.
ORGANIZATIONthe District Court Clerk's Office
ORGANIZATIONEdward Davis
PERSON