EFTA00731431Set 9
2008-07-1066p17,583w
offender from viewing, owning or possessing certain materials." Ch. 97-308, Laws
of Ha. (emphasis added). If anything, this suggests that the Legislature did not
intend to leave the broad ... offender
and his or her deviant sexual history." Staff Analysis at 7-8 (emphasis added)
(quoting NIJ report at 3). The NIJ report also indicates that priorities include
"individualized treatment ... charged with an offense." State v. Byars, 823 So. 2d 740,
742 (Fla. 2002) (emphasis added). As we have emphasized before, "lo]ne of the
most fundamental principles of Florida
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731431.pdf
EFTA01114178Set 9
2015-06-0233p10,670w
promised that
NYGG would help Plaintiff find an apartment." (a. (emphasis omitted)) On December 1, 2013,
3
EFTA01114180
Plaintiff moved into an apartment that Wey found for her in lower ... part of her compensation, and that he
would act as her guarantor." a (emphasis omitted)) Plaintiff assumed that this meant NYGG
was giving her a raise, but she never received ... year-end bonus from NYGG," and then "plied Plaintiff with drinks." at166
(emphasis omitted)) After dinner, Wey accompanied Plaintiff to her apartment, and forced her to
have sexual intercourse with
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114178.pdf
EFTA00022546Set 8
2019-07-2370p21,586w
then bar an
appeal by Epstein of that remedy.
749 F.3d at 1005-06 (emphasis added). Plainly when it ruled in 2014, the Eleventh Circuit foresaw
a situation where Epstein ... F.Supp.2d 1337, 1342 (S.D. Fla. 2011) (quoting 18 U.S.C. § 377(d)(3)
(emphasis added)). This Court explained that the CVRA's language allows CVRA's rights to "be
enforced ... before a prosecution is underway . . ", id. (emphasis added) — i.e., to be "enforced" in
this Court. Of course, the Crime Victims Rights Act creates rights for "crime victims," which in
Epstein
https://www.justice.gov/epstein/files/DataSet%208/EFTA00022546.pdf
EFTA00021442Set 8
2019-07-2370p21,698w
then bar an
appeal by Epstein of that remedy.
749 F.3d at 1005-06 (emphasis added). Plainly when it ruled in 2014, the Eleventh Circuit foresaw
a situation where Epstein ... F.Supp.2d 1337, 1342 (S.D. Fla. 2011) (quoting 18 U.S.C. § 377(d)(3)
(emphasis added)). This Court explained that the CVRA's language allows CVRA's rights to "be
enforced ... before a prosecution is underway . . ", id. (emphasis added) — i.e., to be "enforced" in
this Court. Of course, the Crime Victims Rights Act creates rights for "crime victims," which in
Epstein
https://www.justice.gov/epstein/files/DataSet%208/EFTA00021442.pdf
EFTA00178057Set 9
2011-05-0290p23,378w
accorded, the rights described in [the CVRA]." 18
U.S.C. § 3771(c)(1) (emphasis added). The victims have cited this provision prominently and
repeatedly in their pleadings. See, e.g., Victims' Initial ... court in the
district in which the crime occurred" 18 U.S.C. § 3771(d)(3) (emphasis added). Of course, the
For clarity, the victims will refer to their Motion for Finding ... done enough. That
would be a situation.
July 11, 2008 Tr. at 10-11 (emphasis added). Of course, if the right to be reasonably protected
applies before an indictment, there
https://www.justice.gov/epstein/files/DataSet%209/EFTA00178057.pdf
EFTA01112467Set 9
2010-03-2327p8,263w
know about.
See Razorback Amended Complaint; pp. 16-17;9[48 (emphasis added).
Additionally, Rothstein used RRA's representation in the Epstein case to
pursue issues and evidence unrelated ... effort to bolster
Rothstein's lies.
See Razorback Amended Complaint; page 17; II 49 (emphasis added). All of these
deposition subpoenas and discovery requests to which the Razorback Complaint refers ... Jane Doe No. 2 v. Epstein Dated November 5, 2009, 08-cv-80119 (emphasis
added).
Additionally, as soon as Edwards arrived at RRA, Edwards and his partners set
and/or took
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112467.pdf
EFTA01112494Set 9
2010-03-2327p8,305w
Rothstein
did not yet know about.
See Razorback Amended Complaint; pp. 16-17; ¶ 48 (emphasis added).
Additionally, Rothstein used RRA's representation in the Epstein case to
pursue issues ... deliberate effort to bolster
Rothstein's lies.
See Razorback Amended Complaint; page 17; ¶ 49 (emphasis added). All of these
deposition subpoenas and discovery requests to which the Razorback Complaint refers ... Jane Doe No. 2 v. Epstein Dated November 5, 2009, 08-mi-80119 (emphasis
added).
Additionally, as soon as Edwards arrived at RRA, Edwards and his partners set
and/or took
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112494.pdf
EFTA02729255Set 11
2009-01-0742p10,491w
until the end of all
phases of the criminal action." 18 U.S.C. § 3509(k) (emphasis added).'
1
I I The full text of the mandatory-stay provision reads ... Decl. of AUSA
07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the
Agreement, the USAO presently retains the continuing right to indict Mr. Epstein -
- or to unseal ... unless
and until the defendant violates any term of this agreement." Agreement, at 5
(emphasis added). The Agreement directs the USAO and Epstein to. "maintain
their evidence, specifically evidence requested
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02729255.pdf
EFTA00299022Set 9
2006-07-1953p14,386w
United States, 359 F. Supp. 3d 1201, 1208 (S.D. Fla. 2019) (emphasis added) (DE
435:8) (citing DE 407, at ¶48). From that finding, Petitioners contend that the Court
concluded ... unknown), from the beginning of the world to the day of this
release.
(Emphasis added). Thus, Petitioners expressly released Mr. Epstein from any federal
actions, claims or demands in equity ... they had reached no settlement with the U.S.
Attorney's Office..." (DE 41:1) (emphasis in original). Petitioners did not disclose at that
time that they would seek to engineer
https://www.justice.gov/epstein/files/DataSet%209/EFTA00299022.pdf
EFTA00721915Set 9
2010-12-0617p3,126w
stand out and get noticed.
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EFTA00721921
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https://www.justice.gov/epstein/files/DataSet%209/EFTA00721915.pdf
EFTA01079203Set 9
2016-01-1260p13,979w
Motion to Determine Confidentiality, November 23, 2015,
attached hereto as Exhibit E at 4 (emphasis added). Those "sexual abuse allegations filed by
Edwards and Cassell for their client" go beyond ... must use the least restrictive closure necessary to accomplish its purpose." Id. at 118
(emphasis added); see also Carter v. Conde Nast Pithrtis ... able to prove it and she
will end up in prison for perjury." (emphasis added). See Exhibit 1, New York Daily News, April
7, 2015. Defendant has subjected Jane
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079203.pdf
EFTA00207984Set 9
2011-05-0229p9,189w
accorded, the rights described in [the CVRA]." 18
U.S.C. § 3771(c)(1) (emphasis added). The victims have cited this provision prominently and
repeatedly in their pleadings. See, e.g., Victims' Initial ... court in the
district in which the crime occurred." 18 U.S.C. § 3771(d)(3) (emphasis added). Of course, the
For clarity, the victims will refer to their Motion for Finding ... done enough. That
would be a situation.
July 11, 2008 Tr. at 10-11 (emphasis added). Of course, if the right to be reasonably protected
applies before an indictment, there
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207984.pdf
EFTA01098264Set 9
2011-05-0229p9,339w
accorded, the rights described in [the CVRA]." 18
U.S.C. § 3771(c)(1) (emphasis added). The victims have cited this provision prominently and
repeatedly in their pleadings. See, e.g., Victims' Initial ... court in the
district in which the crime occurred." 18 U.S.C. § 3771(d)(3) (emphasis added). Of course, the
For clarity, the victims will refer to their Motion for Finding ... done enough. That
would be a situation.
July 11, 2008 Tr. at 10-11 (emphasis added). Of course, if the right to be reasonably protected
applies before an indictment, there
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098264.pdf
EFTA00614086Set 9
2011-09-1621p6,470w
Edwards to Robert D. Critton, Jr., Aug. 26, 2010 (Exhibit A to this
pleading) (emphasis added)
One week later, on September 2, 2010, Epstein filed a motion for a protective ... objections to the use of the correspondence in that case." DE 221 at 6 (emphasis added).
On October 20, 2010, this Court (Marra, J.), entered an order (DE 222) remanding ... alleged violations of the Crimiel Victims Rights Act." DE
223 at p. 6 (emphasis added).
On January 5, 2011, Magistrate Judge Johnson entered an order (DE 226) overruling
Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614086.pdf