Epstein Secrets

0799528 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 36 of 101 Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Mauer Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

tution. See In re W.R. Huff, 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

inguish that power by ratification of the contract.") (quoting John E. Murray, Jr., Murray on Contracts § 17, at 31 (3d ed. 1990)); AVVA-BC, LLC v. Amiel, 25 So. 3d 7, 11 (Fla. 3d DCA 2009) ("[W]here a party seeking rescission has discovered grounds for rescinding an agreement and either remains sile

0795204 Case 9:08-cv-80736-KAM Document 205-6 Entered on FLSD Docket 07/05/2013 Page 36 of 1W. Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Mailer Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

tution. See In re W.R. Huff, 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

inguish that power by ratification of the contract.") (quoting John E. Murray, Jr., Murray on Contracts § 17, at 31 (3d ed. 1990)); AVVA-BC, LLC v. Amiel, 25 So. 3d 7, 11 (Fla. 3d DCA 2009) ("[W]here a party seeking rescission has discovered grounds for rescinding an agreement and either remains sile

58-59, 89-90). Petitioners leveraged the NPA to their advantage by arguing that it precluded Mr. Epstein from contesting liability. See Doe No. 1 v. United States, 749 F.3d 999, 1002 (11'h Cir. 2014) ("As a basis for relief against Epstein in the civil suit, the victims relied on Epstein's waiver of his right

y stems from the Constitution's delegation of "take Care" duties, U.S. Const. art. II, § 3, and the pardon power, id. § 2, to the Executive Branch. See United States v. Armstrong, 517 U.S. 456, 464 . . . (1996); In re Aiken Cnty., 725 F.3d 255, 262-63 (D.C.Cir.2013). Decisions to initiate charges, or to dismiss

stent with an intention of avoiding it, have the effect of an election to affirm. Hendricks v. Stark, 99 Fla. 277, 285 (Fla. 1930); AVVA-BC, LLC v. Amiel, 25 So.3d 7, 11 (Fla. 3d DCA 2009) ("[W]here a party seeking rescission has discovered grounds for rescinding an agreement and either remains silen

fice, an event that did not occur until June 2008. DE 48 at 1 41 & Ex. Eat 5. 34 EFTA00208856 Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Mauer Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

tution. See In re W.R. Huff, 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

nguish that power by ratification of the contract."') (quoting John E. Murray, Jr., Murray on Contracts § 17, at 31 (3d ed. 1990)); AVVA-BC, LLC v. Amiel, 25 So. 3d 7, 11 (Fla. 3d DCA 2009) ("[W]here a party seeking rescission has discovered grounds for rescinding an agreement and either remains sile