EFTA00021442Set 8
2019-07-2370p21,698w
district
court shall take up and decide any motion asserting a victim's right forthwith." DE 463 at 40
(citing 18 U.S.C. § 3771(d)(3) (emphasis added)). Epstein, however ... raise — either with this Court or the appellate court — any need for
a "forthwith" ruling then, Epstein cannot belatedly raise such a claim years later.
In any event, relief ... this
Court to "take up and decide any motion asserting a victim's right forthwith," 18 U.S.C. §
3771(d)(3), is undoubtedly designed to ensure that victims can obtain immediate
https://www.justice.gov/epstein/files/DataSet%208/EFTA00021442.pdf
EFTA00022546Set 8
2019-07-2370p21,586w
district
court shall take up and decide any motion asserting a victim's right forthwith." DE 463 at 40
(citing 18 U.S.C. § 3771(d)(3) (emphasis added)). Epstein, however ... raise — either with this Court or the appellate court — any need for
a "forthwith" ruling then, Epstein cannot belatedly raise such a claim years later.
In any event, relief ... this
Court to "take up and decide any motion asserting a victim's right forthwith," 18 U.S.C. §
3771(d)(3), is undoubtedly designed to ensure that victims can obtain immediate
https://www.justice.gov/epstein/files/DataSet%208/EFTA00022546.pdf
EFTA00133182Set 9
2019-12-03167p34,932w
8/14/2019 Verizon Thomas, Noel - 8/16/2019
8 8/14/2019 Ton Noel Epstein documents; location documents; cellphone Forthwith
9 8/14/2019 T-Mobile IP addresses from 4chan 8/16/2019
10 8/14/2019 AT&T IP addresses ... from 4chan 8/16/2019
11 8/19/2019 Michael Thomas Epstein documents; location documents; cellphone Forthwith
12 8/16/2019 Epstein documents. 8/20/2019
13 Not Served Epstein documents. 8/20/2019
14 8/16/2019 Epstein documents. 8/20/2019 ... Southern District of New York, at the following date, time and place:
Appearance Date: FORTHWITH Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged
https://www.justice.gov/epstein/files/DataSet%209/EFTA00133182.pdf
EFTA00024954Set 8
2013-02-0228p4,678w
this time.' The Court should require the defense to provide
supplemental expert notice forthwith or preclude these witnesses from testifying.
I. APPLICABLE LAW
Federal Rule of Criminal Procedure ... closely
scrutinized by the Court, and entirely precluded if notice is not provided forthwith.
A. Robert Kelso and
The defendant anticipates calling Robert Kelso, a computer forensics specialist, to testify ... testimony from Kelso and unless and
until the defense to provides supplemental expert notice forthwith. 12 If the defense does so, the
Government should have an opportunity at that time
https://www.justice.gov/epstein/files/DataSet%208/EFTA00024954.pdf
EFTA01130718Set 9
2012-06-0112p2,742w
court reporter as daily copy and posted by the Trustee on his website
forthwith after the transcript has been received by the Trustee. Each party shall be responsible
for purchasing ... does not need the lull time allotted
pursuant to this Order, that defendant shall forthwith notify Lichtman, so that the deposition
schedule can be modified. Lichtman shall file with this ... Deposition, he
shall file a Notice of Location of Rothstein Deposition in this case, forthwith, which location
shall also be stated in the Notice(s) ofDeposition referenced below.
7. Each
https://www.justice.gov/epstein/files/DataSet%209/EFTA01130718.pdf
EFTA00074599Set 9
2021-04-1569p52,989w
investigation to" the Ombudsman,
and decide any motion asserting a victim's right forthwith."
Id. § 3771(d)(3). And with respect to the latter, it provides who, in turn ... that victims' rights are protected, and it contains no asserting a victim's right forthwith."
suggestion that the Act provides for judicial enforcement of
crime victims' rights outside the confines
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074599.pdf
EFTA01465057Set 10
4p2,842w
obli
gations to the Bank as and when they are due, the Guarantor shall forthwith pay such liabilities or
obligations in immediately available funds without the Bank having any obligation ... tified copy thereof), and (iii) in the case of any such deduction or withholding, forthwith pay to t
he Bank such additional amount as may be necessary to ensure that ... account of any payment made
by the Guarantor under this Guaranty, the Guarantor shall forthwith pay that amount received by it
to the Bank, to be credited and applied against
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01465057.pdf
EFTA01188913Set 9
2002-12-3036p12,966w
other amounts payable under
each Note or any Loan Document to be forthwith due and payable, whereupon each Note, all
such interest and all such amounts shall become ... forthwith due and payable, without
presentment, demand, protest or further notice of any kind, all of which are hereby expressly
waived by Borrower; and any obligation of Bank to permit ... whereupon each
Note, all such interest and all such an: dints sh:e une forthwith due and payable,
without presentment, demand. protest or further c of .• - hind, all of which
https://www.justice.gov/epstein/files/DataSet%209/EFTA01188913.pdf
EFTA02707722Set 11
2002-12-3036p12,965w
other amounts payable under
each Note or any Loan Document to be forthwith due and payable, whereupon each Note, all
such interest and all such amounts shall become ... forthwith due and payable, without
presentment, demand, protest or further notice of any kind, all of which are hereby expressly
waived by Borrower; and any obligation of Bank to permit ... payable, whereupon each
Note, all such interest and all tuch 'tints slc, nne '•c forthwith due and payable,
without presentment, demand. protest or funlici . of . Lind, all of which
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02707722.pdf
EFTA00078450Set 9
2019-08-122p594w
Southern District of New York, at the following date, time and place:
Appearance Date: FORTHWITH Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged ... bring with you and produce at the above time and place the following:
URGENT - FORTHWITH SUBPOENA.
Personal appearance is required unless excused by the U.S. Attorney's Office ... York 10007
rev. 02.01.12
EFTA00078450
RIDER
(Grand Jury Subpoena to dated August 12, 2019)
FORTHWITH SUBPOENA
Advice of RiitIns
1. You may refuse to answer any question if a truthful
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078450.pdf
EFTA00075342Set 9
2019-08-142p598w
Southern District of New York, at the following date, time and place:
Appearance Date: FORTHWITH Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged ... bring with you and produce at the above time and place the following:
URGENT - FORTHWITH SUBPOENA.
Personal appearance is required unless excused by the U.S. Attorney's Office ... EFTA00075342
RIDER
(Grand Jury Subpoena to Tova Noel, dated August 14, 2019)
FORTHWITH SUBPOENA
Advice of Rights
1. You may refuse to answer any question if a truthful answer
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075342.pdf
EFTA00616595Set 9
2007-04-1131p8,896w
purchaser fails to close this transaction as specified, the
escrow agent is directed to forthwith pay the escrow deposit to the seller and broker in
accordance with their agreement ... shall have the right of specific performance. Upon Seller's default, the
Seller shall forthwith pay to Broker(s) the full commission provided for under the terms of the
listing ... shaft have the right of specific performance. upon Seller's default, the
Seller shall forthwith pay to Broker(s) the full commission provided for under the terms of the
listing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00616595.pdf