Epstein Secrets

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

ciency of a pleading." Fed. R. Civ. P. 9(f). The oNy case cited by BIC with regard to Rule 9(I) is MiCOl Indus_ Inc. v. C2JS Holdngs. Inc.. in which the Northern District of Alabama briefly summarized the allegations in the complaint before it and found that it satisfied the requirements of Rules 9(b) and 9(t). Miser

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

victims of various federal crimes related to fraud, securities crimes, and money laundering, among others, and that the U.S. Attorney's Office for the Northern District of Indiana had "refused to confer with them, denied them their right to full and timely restitution, . .. and demonstrated 'a total indifference and

he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t

Eleventh, and Federal Circuit Courts of Appeals. and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. lam currently employed as an Assistant United States Atto