Epstein Secrets

mes and in any copies of the draft NPA Also, do you have any objections to redacting my personal email address and personal cell phone numbers in Bates numbers 005, 016, 026-030, 039, 056, 062, 072, 073, 088, 090, 097-098, 177, 180? You may not know that prisoners have access to PACER. EFTA00212521

n particular Senate of the Commonwealth of Puerto Rico United States Dep't of Justice, 1992 WL 119127 at *3 (D.D.C. May 13, 1992) and United States g Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999), I believe that the following portions of your Exhibit A should remain under seal (and any related portio

s " and in any copies of the draft NPA Also, do you have any objections to redacting my personal email address and personal cell phone numbers in Bates numbers 005, 016, 026-030, 039, 056, 062, 072, 073, 088, 090, 097-098, 177, 180? You may not know that prisoners have access to PACER. Thank you!

in particular Senate of the Commonwealth of Puerto Rico United States Dep't of Justice, 1992 WL 119127 at *3 (D.D.C. May 13, 1992) and United States. Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999), I believe that the following portions of your Exhibit A should remain under seal (and any related portio

off, and in any copies of the draft NPA Also, do you have any objections to redacting my personal email address and personal cell phone numbers in Bates numbers 005, 016, 026-030, 039, 056, 062, 072, 073, 088, 090, 097-098, 177, 180? You may not know that prisoners have access to PACER. Thank you!

icular Senate of the Commonwealth of Puerto Rico v. United States Dep't of Justice, 1992 WI_ 119127 at *3 (D.D.C. May 13, 1992) and United States v. Anderson, 55 F. Stipp. 2d 1163, 1168 (D. Kan. 1999), I believe that the following portions of your Exhibit A should remain under seal (and any related porti

mes and in any copies of the draft NPA Also, do you have any objections to redacting my personal email address and personal cell phone numbers in Bates numbers 005, 016, 026-030, 039, 056, 062, 072, 073, 088, 090, 097-098, 177, 180? You may not know that prisoners have access to PACER. Thank you!

ticular Senate of the Commonwealth of Puerto Rico v. United States Dep't of Justice, 1992 WL 119127 at •3 (D.D.C. May 13, 1992) and United States v. Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999), I believe that the following portions of your Exhibit A should remain under seal (and any related portio

gument that it should be stricken as redundant of other claims. (1d. at 5.) Accordingly, with respect to Count VI, the undersigned construes BTU and Bates motion as asserting the redundancy argument, only. II. Motion to Dismiss Standard Pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure

nonmoving party to identify specific facts from which a factfinder could reasonably find in the nonmoving party's favor. Celotex, 477 U.S. at 324; Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 252, 106 S. Ct. 2505, 91 L. Ed. 2d 202 (1986). In determining whether the factfinder could reasonably find in

e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min

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

e attached as Exhibit J to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp).' Because Epstein has moved to keep these documents from the public, they are at this time filed under seal with the Court. Threugh-

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