EFTA00294815Set 9
2002-10-2832p9,752w
ofevery kind nature and description in 100% of the Shares owned by the Assignor." (Exh. K at
1) (emphasis added).
Thus, COUQ no longer holds an interest ... times the net asset
value of investments on a gross basis. (See e.g., Exh. L at 9; Exh. Mat 15). In addition, with
respect to the EL Fund, potential investors ... generally up to . 27.5 times the Net Asset
Value of the Master Fund." (Exh. M at 14). Many of the parties that extended leverage to the
HG Funds were "repo
https://www.justice.gov/epstein/files/DataSet%209/EFTA00294815.pdf
EFTA01093175Set 9
2010-01-1933p7,881w
fetuses is more traumatic than giving a man a
massage in the nude.
(Transcript, Exh. 2, pp. 301-305). While it may not be inappropriate to ask a plaintiff ... Proposal for Settlement that was served on Plaintiffs' counsel in March, 2009. (Transcript, Exh.
1, p. 71). He proceeds to ask Jane Doe No. 4 a series of questions about ... Plaintiffs' counsel pursuant to
Fed.R.Civ.P. 26(a)(2) and Fed.R.Evid. 702. (Transcript, Exh. 2, pp. 237-244, 267). Defendant's
counsel had previously received extensive expert discovery from
https://www.justice.gov/epstein/files/DataSet%209/EFTA01093175.pdf
EFTA00615480Set 9
2016-06-209p2,381w
each woman wishes
anonymity. Tiffany Doe, a witness, was an employee of Defendant Epstein. Exh. B.
8. Courts have discretion to allow proceeding anonymously where the need for
privacy outweighs ... Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the
ten factors that the Second Circuit articulated as relevant to this ... Defendant Jeffrey Epstein. At least four of the parties were attended by
Defendant Trump. Exhs. A and B. On information and belief, by this time in 1994, Defendant
3
EFTA00615482
https://www.justice.gov/epstein/files/DataSet%209/EFTA00615480.pdf
EFTA00211168Set 9
2016-06-2013p4,082w
each woman wishes
anonymity. Tiffany Doe, a witness, was an employee of Defendant Epstein. Exh. B.
8. Courts have discretion to allow proceeding anonymously where the need for
privacy outweighs ... Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the
ten factors that the Second Circuit articulated as relevant to this ... Defendant Jeffrey Epstein. At least four of the parties were attended by
Defendant Trump. Exhs. A and B. On information and belief, by this time in 1994, Defendant
3
EFTA00211170
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211168.pdf
EFTA01192541Set 9
2011-07-025p1,751w
NO.6 STRUT 200-72-54-00 RPR $ 16.00 $ 128.00
8 760015 NUT STRUTS TURB EXH. 200-72-54-00 RPR $ 24.00 $ 192.00
1 762494 NO.3 INVERTED ... BRG.HOUSING 200-72-41-00 SV $ 2,800.00 $ 2,800.00
8 753722 SCREW,FAN EXH DUCTS 200-72-54-00 NE $ 13.10 $ 104.80
8 759955 BRG EXH, STRU ... ASSY BRTHR NO4 200-75-00-00 SV $ 350.00 $ 350.00
5 779910 STRUT FAN EXH. 200-72-54-00 SV $ 700.00 $ 3,500.00
1 788929 DUCT ASSY,OUTER
https://www.justice.gov/epstein/files/DataSet%209/EFTA01192541.pdf
EFTA00065989Set 9
2002-04-2638p11,008w
Acosta's handling of the Epstein
case, characterized the NPA as a "unique resolution." Exh. B (Dep't of Justice, Office of
Professional Responsibility, Executive Summary of Report, Investigation into ... revealed that during these negotiations, several drafts
of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz
attaching draft NPA); Exh. D (9/21/07 email from ... agreement under
which Epstein would have pled guilty to a federal offense. See, e.g., Exh. E (9/15/07 email from
Villafana to Lefkowitz attaching draft information and plea agreement); Exh
https://www.justice.gov/epstein/files/DataSet%209/EFTA00065989.pdf
EFTA00204755Set 9
1997-05-094p1,328w
diplomat of the government of Iran
(Declaration of Richard C. Massey ("Massey Dec."), Exh. A thereto). As such, they were recognized as consular
property by the United States Department ... State ("State Department"), Office of Foreign Missions ("OFM")
(Massey Dec., Exh. A thereto), and enjoyed the protection of the Foreign Missions Act ("FMA"), ss& 22 U.S.C ... granted to OFM by the Treasury Department,
Office of Foreign Assets Control (Massey Dec., Exh. B thereto). OFM is empowered to bring this action to seek
equitable relief to protect
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204755.pdf
EFTA00223063Set 9
1997-05-094p1,339w
diplomat of the government of Iran
(Declaration of Richard C. Massey ("Massey Dec."), Exh. A thereto). As such, they were recognized as consular
property by the United States Department ... State ("State Department"), Office of Foreign Missions ("OFM")
(Massey Dec., Exh. A thereto), and enjoyed the protection of the Foreign Missions Act ("FMA"), ss& 22 U.S.C ... granted to OFM by the Treasury Department,
Office of Foreign Assets Control (Massey Dec., Exh. B thereto). OFM is empowered to bring this action to seek
equitable relief to protect
https://www.justice.gov/epstein/files/DataSet%209/EFTA00223063.pdf
EFTA01325003Set 10
1998-02-025p1,324w
requested relief (see Declaration of Serene K. Nakano ("Nakano Dec.") 118 & n.2; Exh.
G thereto).
SONY_GM_02742788
EFTA_00229437
EFTA01325003
STATEMENT OF FACTS
A. Government's Protection Of Premises ... diplomat of
the government of Iran (Declaration of Richard C. Massey ("Massey Dec."), Exh. A
thereto). As such, they were recognized as consular property by the United States
Department ... State ("State Department"), Office of Foreign Missions ("OFM") (Massey
Dec., Exh. A thereto), and enjoyed the protection of the Foreign Missions Act ("FMA"),
see 22 U.S.C
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01325003.pdf
EFTA00099352Set 9
2002-04-2638p10,958w
investigating Acosta's handling of the Epstein
case, characterized the NPA as "unique resolution." Exh. B (Dep't of Justice, Office of
I
Professional Responsibility, Executive Summary of Report, Investigation ... revealed that during these negotiations, several drafts
of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz
attaching draft NPA); Exh. D (9/21/07 email from ... agreement under
which Epstein would have pled guilty to I federal offense. See, e.g., Exh. E (9/15/07 email from
Villafana to Lefkowitz attaching draft information and plea agreement); Exh
https://www.justice.gov/epstein/files/DataSet%209/EFTA00099352.pdf
EFTA00801426Set 9
2011-04-1434p9,651w
dismiss the First Amended
Complaint ("FAC") filed by plaintiff Jane Doe ("Plaintiff'). Exh. A.
The FAC represents Plaintiffs second unsuccessful bite at the apple. On January 26,
2017, Plaintiff filed ... original complaint in this matter ("Complaint"). Exh. B. On May 15,
2017, and at the suggestion of the Court, Defendants served a letter on Plaintiff identifying a
wide range ... deficiencies warranting dismissal of the Complaint ("Deficiency Letter"). Exh. C.
On June 5, 2017, Plaintiff filed the FAC — without fixing the deficiencies cited in the Deficiency
Letter.
Indeed, just like
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801426.pdf
EFTA00307096Set 9
2017-01-2625p7,457w
apple. On January 26,
2017, Plaintiff filed her original complaint in this matter ("Complaint"). Exh. On May 15,
2017, and at the suggestion of the Court, the Defendants served ... Plaintiff identifying a
wide range of deficiencies warranting dismissal of the Complaint ("Deficiency Letter"). Exh.
. On June 5, 2017, Plaintiff filed the FAC, purportedly to correct the deficiencies ... comparison of these same paragraphs as set forth in
the Complaint FAC. Exh.
2 Assuming arguendo that Plaintiff's reliance on Epstein's representations was ever reasonable,
her reliance certainly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307096.pdf
EFTA00204759Set 9
1997-12-178p6,452w
potential for damage to
the premises from a short-term tenant occupancy." (Schantz Aff., Exh. D). OFM did, however, grant Epstein
permission to sublet the Premises to Galinas ... person to use the Premises with the advance written
permission of Landlord." (Massey Decl., Exh. B at 4) (emphasis added). Epstein's and Fisher's argument that
the word
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204759.pdf