Epstein Secrets

4-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 54 Respondent's Exhibit

bserved that, "[f]actual admissions can be binding as judicial admissions; admissions of legal conclusions cannot." Id.(citations omitted). See also Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. III. 1999)("It is well established that judicial admissions on questions of law have no legal

rad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney College of Law at the Salt Lake City, Utah 84112 Attorneys for Jane Doe # 1 and Jane Doe # 2 Since no criminal case was pending, the Clerk's Office filed the Emergency Petition as a ci

served that, "[f]actual admissions can be binding as judicial admissions; admissions of legal conclusions cannot." Id. (citations omitted). See also Dabertin v. HCR Manor Care, Inc. , 68 F.Supp.2d 998, 1000 (N.D. III. 1999)("It is well established that judicial admissions on questions of law have no lega

a 33301 Tel: E-mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Tel: E-mail: [email protected] Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201

s of subordinate employees in the DOJ were considered judicial admissions, a party's judicial admissions on questions of law have no legal effect.6 Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. Ill. 1999). Plainly, at the time the NPA was negotiated in 2007, the then-current version of

nue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 54 EFTA00078888

bserved that, "[f]actual admissions can be binding as judicial admissions; admissions of legal conclusions cannot." Id.(citations omitted). See also Dabertin v. HCR Manor Care, Inc., 68 F.Supp.2d 998, 1000 (N.D. Ill. 1999)("It is well established that judicial admissions on questions of law have no legal