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t be: an "efficient and compelling purpose," United States v. Meacham, 115 F.3d 1488, 1495 (10' Cir. 1997); a "motivating purpose," United States v Campbell, 49 F.3d 1079, 1083 (56 Cir. 1995), or "at least one of the defendant's motivations for taking the trip in the first place," United States v Ellis,
y precludes the initiation or continuation of a federal prosecution, following a prior state or federal prosecution based on substantially the same act(s) or transaction(s) unless three substantive prerequisites are satisfied: first, the matter must involve a substantial federal interest; second, th
al conduct must be: an "efficient end compelliog purpos United States' Meacham 115 F.3d 1488, 1495 (10°' Cir. 1991); a "motivating purpose," Unitt. Campbell 49 F.3d 1079, 1083 (5° 1995), or "at least one of the defendant's motivations for taking the trip in the first place," United States I. Ellis 935 F
y precludes the initiation or continuation of a federal prosecution, following a prior state or federal prosecution based on substantially the same act(s) or transaction(s) unless three substantive prerequisites are satisfied: first, the matter must involve a substantial federal interest; second, th
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. Liqoet Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the United St
tify that Plaintiff was paid by others for similar sexual acts she claims Mr. Epstein forced upon her or that she willingly participated in certain act(s) that would negate or lessen her damages. This goes directly to Plaintiff's damage claim. 7. Likewise, subpoenas must be issued to third-party tre
Entities connected to both Naomi Campbell and act(s

Jeffrey Epstein
PERSON
George W. Bush
PERSON
United States
LOCATION
Julie K. Brown
PERSONLeon Black
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
George Mitchell
PERSON
New York
LOCATION
Vicky Ward
PERSONEmmy Taylor
PERSON
Department of Justice
ORGANIZATION
New York City
LOCATION
Barry Diller
PERSONJane Doe
PERSONJack Goldberger
PERSON