Epstein Secrets

n at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of 2007. (

rty. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress

n at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA Sloman, requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of

rty. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress

n at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA I I, requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of 20

rty. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress

n at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA Sloman, requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of

rty. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress

n at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA Sloman, requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of

rty. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress

torney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. The U.S. Attorney's Office did not confer with any of the victims about these modifications of the agreement (or even notify them of the existence

disputes. Construing the CVRA in the way that d'See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States): United States I Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United States, distri

orney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental Declaration of A. Marie Villafafia, doe. #35, at 1; U.S. Attorney's Correspondence at 234-37. The—‘65,4atemeyss—Offiee-414--rtet-

e process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation.") (quoting United States'. Anderson, 799 F.2d 1438, 1441(11'h Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery materials were not availa

n at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of 2007. (

arty. Celotex Corp. v. Catrett 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress

n at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of 2007. (

arty. Celotex Corp. v. Catrett 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress