rly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, Epstein — a sex offender who worked with the USAO-SDFL to illegally conceal an 47 EFTA00021491 --- PAGE BREAK

rly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, Epstein — a sex offender who worked with the USAO-SDFL to illegally conceal an 47 EFTA00022595 --- PAGE BREAK

ly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, the Government has unclean hands for multiple reasons — as argued at length in the victims' summary judgment moti