Epstein Secrets

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dant, and for which Defendant expressly agreed to pay pursuant to a Non-Prosecution Agreement that he entered into with the United States Attorney's Office for the Southern District of Florida. Plaintiff further alleges: ALLEGATIONS PERTAINING TO ALL COUNTS Jurisdiction I. Plaintiff, Podhurst Orseck, P.A. ("Podhurst firm" or

OLD DAVID J. HARDY WM SCOTT WICKLINE PAMELA L. CAMPBELL PAMELA C DEEM PHILIP J. CO/ABS STEPHANE D. THI

of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive

r ppellec/Responlent MOVING ATTORNEY: Kerrie L. Campbell [name of attorney, whh firm, address. glione num

987) 4, 5, 8 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) 4 Miller v. City of Ithaca, No. 10 Civ. 597 (TJM), 2013 WL 12310711 (N.D.N.Y. May 8, 2013) 6 Nixon v. Warner Commc 'us, Inc., 435 U.S. 589 (1978) 4, 5, 6 Scott v. Graham, No. 16 Civ. 2372 (KPF) (JLC), 2016 WL 6804999 (S.D.

stewardship as vital to the club's future. Judge Naomi Reice Buchwald of Federal District Court in Manha

or girls experienced horrible sexual abuse and rape in Florida. But then Epstein was given a slap-on- the-wrist deal in 2008 from the U.S. Attorney's Office for the Southern District of Florida and some of his co- conspirators were shielded from prosecution. To make matters even worse, that deal seems to have been the product of

stewardship as vital to the club's future. Judge Naomi Reice Buchwald of Federal District Court in Manha

or girls experienced horrible sexual abuse and rape in Florida. But then Epstein was given a slap-on- the-wrist deal in 2008 from the U.S. Attorney's Office for the Southern District of Florida and some of his co- conspirators were shielded from prosecution. To make matters even worse, that deal seems to have been the product of

guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996)• Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007)• State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the United St

EFTA00182828 Page 18 of 20 908 F.Supp. 1265 908 F.Supp. 1265 (Cite as: 908 F.Supp. 1265) Memorandum of Decision and Order, October 19, 1995 (E.D.N.Y.). In Brechner, a defendant subjec- ted to a similar truthfulness obligation was asked in a debriefing session whether or not he had received unrepo