Epstein Secrets

To: Albano, Jonathan M HaaSc ac ter, Mic C. Cc ; (USANYS) Subject: U v. a o - a nc. o ion to Intervene [EXTERNAL EMAIL] Counsel, ; Peng, Victoria ; Steve oore, Mark Please find attached the Government's opposition to Oath Ines motion to intervene for the limited purpose of obtaining materia

n v Maxwell.doc Dear Counsel: Would you please let me know if you have any objection to my filing with the Court a copy of the attached decision of the Second Circuit in Brown v. Maxwell (July 3, 2019)? Thank you, and have a good weekend. Jon Jonathan M. Albano Morgan, Lewis & Bockius LLP 10-1726 www.morganl

achments: Brown v Maxwell.doc Sounds fine to me From: 1‘.e Sent: Friday, August 2, 2019 : . To Haney chachter, Michael C. al=1 1:>; ; Peng, Victoria Subject: RE: US v. Gatto - Oath Inc. Motion to Intervene >; Steve 1oore, Mark Dear Counsel: Would you please let me know if you have any objectio

ve 1oore, Mark Dear Counsel: Would you please let me know if you have any objection to my filing with the Court a copy of the attached decision of the Second Circuit in Brown v. Maxwell (July 3, 2019)? Thank you, and have a good weekend. Jon Jonathan M. Albano Morgan, Lewis & Bockius LIP One Federal Street I Bo

t of the Princes’ ac- tions. [22-24] Pursuant to the Second Cir- cuit’s instruction, the Court must first de- termine whe

very least, discovery should be ordered circumspectly and only to verify allega- tions of specific facts crucial to an immuni- ty determination.”)). The Second Circuit has instructed “that generally a plaintiff may be allowed limited discovery with re- spect to the jurisdictional issue; but until [plaintiff] has sho

CO is an unusually potent weapon . ‘courts should strive to flush out frivo- lous RICO allegations at an early stage of the litigation.’” Katzman v. Victoria’s Se- cret, 167 F.R.D. 649, 655 (S.D.N.Y.1996). [74] The Federal complaint asserts a RICO claim under § 1962(a), which states in part: “It shall be

efendants had pled guilty to embezzlement and tax evasion. Both defendants appealed, but one of the defendants died while his appeal was pending in the Second Circuit. The Court of Appeals rule that under the rule of abatement, the judgment of conviction against the deceased defendant was required to be vacated a

man named Jeffrey Epstein, who was the owner of Victoria's Secret. The booker told me that Mr. Epstein cou