EFTA00103709Set 9
2018-08-0925p6,523w
Landgraf v. USI Film Prod.,
511 U.S. 244 (1994) passim
Lattab v. Ashcroft,
384 F.3d 8 (1st Cir. 2004) 7
Leocal v. Ashcroft,
543 U.S. 1 (2004) 13
Martin ... EFTA00103711
Stogner v. California,
539 U.S. 607 (2003) 10
Thom v. Ashcroft,
369 F.3d 158 (2d Cir. 2004) 10
Toussie v. United States,
397 U.S. 112 (1970) passim
United States ... structure and legislative history"
as part of first Landgraf step); see also Lattab v. Ashcroft, 384 F. 3d 8, 14 (1st Cir. 2004) ("our
inquiry is not limited
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103709.pdf
EFTA00102999Set 9
2019-03-26239p78,398w
Film Products,
511 U.S. 244 (1994) 35,36,41,42
Leocal v. Ashcroft,
543 U.S. 1 (2004) 56, 57
Madanes v. Madanes,
186 F.R.D. 279 (S.D.N.Y. 1999) 141
Martindell ... Taylor v. United States,
495 U.S. 575 (1990) 56
Thom v. Ashcroft,
369 F.3d 158 (2d Cir. 2004) 47
Toussie v. United States,
397 U.S. 112 (1970) 48
United State
https://www.justice.gov/epstein/files/DataSet%209/EFTA00102999.pdf
EFTA01098959Set 9
2012-08-1017p6,168w
Ashcroft v. lqbal, [56 U.S. 662, 129 S. Ct. 193"; 173 L.Ed. 2d 868 (2009)], the
United States Supreme Court interpreted [Federal Rule of Ci vii Procedure] Rule ... true, to `state a claim for relief that is Malaita,. on its face.' "Ashcroft v. lqbal,
129 S. Ct. at 1949 (citing Avombly, 550 U.S. at 570) (emphasis added ... liable for the misconduct alleged and thus declaratory relief can •urt
be granted. Ashcroft v. lqbal,
129 S.Ct. 1937 (citing Twombly, 550 U.S. at 556).
As such, Count
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098959.pdf
EFTA00204816Set 9
2007-07-134p1,948w
matter has been for show.
Nor are your arguments that I have violated the Ashcroft memo, the USAM or any other policy well taken. As
Chief of the Criminal Division ... exercise appropriate discretion
in deciding whether certain pleas are appropriate and consistent with the Ashcroft memo and the USAM -- not
you.
As for your statement that my concerns about this ... unacceptable to the FBI,
ICE, the victims, and me. These plea negotiations violate the Ashcroft memo, the U.S. Attorney's Manual, and all
of the various iterations of the victims
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204816.pdf
EFTA00191148Set 9
2013-06-1951p14,521w
matter has been for show.
Nor are your arguments that I have violated the Ashcroft memo, the USAM or any
other policy well taken. As Chief of the Criminal Division ... exercise appropriate discretion in deciding
whether certain pleas are appropriate and consistent with the Ashcroft memo and
the USAM -- not you.
As for your statement that my concerns about this ... unacceptable to the FBI, ICE, the
victims, and me. These plea negotiations violate the Ashcroft memo, the U.S.
Attorney's Manual, and all of the various iterations of the victims
https://www.justice.gov/epstein/files/DataSet%209/EFTA00191148.pdf
EFTA00204798Set 9
2007-07-063p842w
been for show.
EFTA00204798
Nor are your arguments that I have violated the Ashcroft memo, the USAM or any other policy well taken. As
Chief of the Criminal Division ... exercise appropriate discretion
in deciding whether certain pleas are appropriate and consistent with the Ashcroft memo and the USAM -- not
you.
As for your statement that my concerns about this ... unacceptable to the FBI,
ICE, the victims, and me. These plea negotiations violate the Ashcroft memo, the U.S. Attorney's Manual, and all
of the various iterations of the victims
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204798.pdf
EFTA00204796Set 9
2007-07-052p836w
matter has been for show.
Nor are your arguments that I have violated the Ashcroft memo, the USAM or any other policy well taken. As Chief of the
Criminal Division ... exercise appropriate discretion in deciding whether
certain pleas are appropriate and consistent with the Ashcroft memo and the USAM — not you.
As for your statement that my concerns about this ... unacceptable to the FBI, ICE, the victims, and
me. These plea negotiations violate the Ashcroft memo, the U.S. Attorney's Manual, and all of the various iterations of the
victims
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204796.pdf
EFTA00204812Set 9
2007-07-134p1,810w
matter has been for show.
Nor are your arguments that I have violated the Ashcroft memo, the USAM or any other policy well taken. As
Chief of the Criminal Division ... exercise appropriate discretion
in deciding whether certain pleas are appropriate and consistent with the Ashcroft memo and the USAM -- not
you.
As for your statement that my concerns about this ... unacceptable to the FBI,
ICE, the victims, and me. These plea negotiations violate the Ashcroft memo. the U.S. Attorney's Manual. and all
of the various iterations of the victims
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204812.pdf
EFTA00204808Set 9
2007-07-134p1,673w
matter has been for show.
Nor are your arguments that I have violated the Ashcroft memo, the USAM or any other policy well taken. As
Chief of the Criminal Division ... exercise appropriate discretion
in deciding whether certain pleas are appropriate and consistent with the Ashcroft memo and the USAM -- not
EFTA00204809
you.
As for your statement that my concerns about ... unacceptable to the FBI,
ICE, the victims, and me. These plea negotiations violate the Ashcroft memo, the U.S. Attorney's Manual, and all
of the various iterations of the victims
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204808.pdf
EFTA00136851Set 9
2020-10-2041p20,474w
Missouri Times <https://themissouritimes.com/ashcroft-preparing-missouris-election-defenses/> (10/19)
reports that in Missouri, "Secretary of State Jay Ashcroft is working with national, state and local leaders to
bolster the state's defenses ... lead up to the Nov. 3 general election." Ashcroft said, "Our office is working
hand-in-hand with federal, state and local officials to safeguard the integrity of Missouri
https://www.justice.gov/epstein/files/DataSet%209/EFTA00136851.pdf
EFTA01825460Set 10
2010-03-081p187w
PETER MANDELSON
From: Jeffrey Epstein
Sent Mon 3/8/2010 11:53:53 AM
Ashcrofts " British Caribbean Bank", would be easier to trash. Ask B.S. Ong, if it were part ... lending group in the harks. . otherwise a civil proceeding that required production of
Ashcrofts emails to . might be helpful ( they are not privileged. in addition, his-
Stargate co ( Belize ) transfers
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01825460.pdf
EFTA00746371Set 9
2010-03-081p191w
jeevacation@gmail.com>
To: PETER MANDELSON
Subject:
Date: Mon, 08 Mar 2010 11:53:53 +0000
Ashcrofts " British Caribbean Bank", would be easier to trash. Ask B.S. Ong, if it were part ... lending
group in the turks. . otherwise a civil proceeding that required production of Ashcrofts emails to his son Andrew.
might be helpful ( they are not privileged. in addition, his- Stargate
https://www.justice.gov/epstein/files/DataSet%209/EFTA00746371.pdf
EFTA00801426Set 9
2011-04-1434p9,651w
Anderson v. Davis Polk & Wardwell LLP,
850 F. Supp. 2d 392 (S.D.N.Y. 2012) 5
Ashcroft v. Iqbal,
129 S. Ct. 1937 (2009) 23
Ashland Inc. v. Morgan Stanley ... forth in Bell Atlantic Corp. v.
Twombly, 127 S. Ct. 1955 (2007) and Ashcroft v. lqbal, 129 S. Ct. 1937 (2009). Under these two
decisions, as explained and applied
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801426.pdf
EFTA00028903Set 8
2021-01-1122p6,173w
Landgraf v. USI Film Products,
511 U.S. 244 (1994) passim
Leocal v. Ashcroft,
543 U.S. 1 (2004) 11
Martin v. Hadix,
527 U.S. 343 (1999) 6
Nijhawan v. Holder ... with elements that
necessarily entail fraudulent or deceitful conduct") (internal punctuation omitted); Leocal v.
Ashcroft, 543 U.S. 1, 7 (2004) (stating that "offense that ... involves" language "requires us to
look
https://www.justice.gov/epstein/files/DataSet%208/EFTA00028903.pdf
EFTA02528773Set 11
2010-03-074p730w
Subject: Re:
Vince Cable, t=e Liberal Democrat Treasury spokesman, said that Lord Ashcroft's failure=to bring all of his finances
onshore had cost taxpayers £100 million ... Ashcrofts money form Tory pocket back to its source.. don't pass g=„
collect winnings
On Sun, Mar 7, 2010 at 6:22 AM, Jeffrey Epst=in <jeevacat=on@gmail.com
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02528773.pdf
EFTA00595583Set 9
2015-11-3029p8,962w
S.D.N.Y. 2013) 7
Armstrong v. Simon & Schuster, Inc., 625 N.Y.S.2d 477 (1995) 7
Ashcroft v. lqbal, 129 S. Ct. 1937, 1949 (2009) 6
Bell Atlantic Corp. v. Twombly ... factual matter...to 'state a
claim to relief that is plausible on its face.'" Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009)
4
Available at http://www.nydailynews.cominews/worldialleged-madame-accused-supplyingprince-
andrew
https://www.justice.gov/epstein/files/DataSet%209/EFTA00595583.pdf