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Organization referenced in documents
EFTA00207332
d on April 13, 2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in Jane Doe's favor") (see other examples Carr
tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (Doe's Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of state
EFTA00728009
ed on April 13.2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in favor") (see other examples Carroll Reply
tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (- Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of statement
EFTA00207294
for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and "[y]ou digitally penetrated Plaintiff when she was a minor," SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of
EFTA00612027
tein's silence in the face of such confrontational Requests for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of

Jeffrey Epstein
PersonAmerican sex offender and financier (1953–2019)
Gallo Winery
OrganizationOrganization referenced in documents

Bradley Edwards
PersonAmerican attorney who represented Epstein victims, author of Relentless Pursuit
E.D. Tenn. 2008
OrganizationOrganization referenced in documents

Michael Fisten
PersonPerson referenced in documents
Scott Rothstein
PersonAmerican criminal

George W. Bush
PersonPresident of the United States from 2001 to 2009

PACER
OrganizationOrganization referenced in documents

Alberto Gonzales
Person80th United States Attorney General

New York Daily News
OrganizationDaily tabloid newspaper in New York City
National Broad.
OrganizationOrganization referenced in documents
Loretta A. Preska
PersonFederal judge, Southern District of New York, presided over Epstein-related proceedings
Jane Doe
PersonPseudonym for anonymous victims/witnesses in Epstein legal proceedings

Johns
PersonSurname reference in Epstein-related documents

Houston
LocationSeat of Harris County, and largest city in State of Texas, United States

Bernie Sanders
PersonUnited States Senator from Vermont since 2007
Gallo
PersonSurname reference in Epstein-related documents

Sergey Brin
PersonAmerican billionaire businessman (born 1973)
Berger
PersonSurname reference to multiple individuals: Bill Berger (victims attorney), Yvonne Berger (Brad Wechsler associate), and references in SEC whistleblower complaints

the United States District Court
OrganizationU.S. federal trial court with jurisdiction over federal cases