EFTA00205624Set 9
2008-07-1137p11,998w
STATES,
Respondent.
UNITED STATES' SEALED REPLY IN SUPPORT OF ITS
MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
In their Response to Government's Sealed Motion to Dismiss ... Lack ofSubject Matter
Jurisdiction (DE 127) and their Sealed Supplemental Response Regarding Remedies ("Sealed
Resp."), Petitioners attempt to establish both their standing in these proceedings and this Court's
subject ... matter jurisdiction over the proceedings. Notwithstanding Petitioners' arguments,
however, this Court lacks subject matter jurisdiction over these proceedings because Petitioners
lack Article III standing and because the claims raised
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205624.pdf
EFTA00624997Set 9
2007-04-1636p9,490w
MANAGEMENT HOLDINGS. LP
CONCLUSION OF EQUITY INTEREST
AS OF APRIL 16. 2007
Assets
Applicata Lack of
Aggregate Marketable Pi9Plagale Fair Partrwes Pro Pro Rata Fair % Ealaltb9 Asset
stadtMablMY
Discount Marble ... Less' Investment Company Discount
$955,655.975
Mmodly marketable Vona
10.0% (595.565598)
Lets Lack of Martrelabily Discount
3860,090.378
Fat Merkel Vas, 01 33.05% Interest an AMILP
5860,100,000
Fair ... Marketable Value of Partners' Capital $0
Partners Pro Rata Percentage 30.35% SO
Discount for Lack of Marketability 10% $0
Pro Rata, Fair Market Value of Partners Capital $0
Pro Rata
https://www.justice.gov/epstein/files/DataSet%209/EFTA00624997.pdf
EFTA00095871Set 9
2019-07-1146p15,250w
government in support of its argument on this
point expressly acknowledge this lack of substantiation. See Jane Doe #1 and Jane Doe #2 v.
United States ... products capable of triggering nuclear weapons and exported
them to Pakistan, despite defendant's lack of any ties to the United States, despite finding
that defendant had "no ties ... Petitioners,
vs.
UNITED STATES,
Respondent.
UNITED STATES' SEALED MOTION TO DISMISS
FOR LACK OF SUBJECT MATTER JURISDICTION
The United States hereby requests that this Court enter an order dismissing these
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095871.pdf
EFTA00100337Set 9
2013-07-0520p5,210w
Petitioners,
vs.
UNITED STATES,
Respondent.
UNITED STATES' SEALED MOTION TO DISMISS
FOR LACK OF SUBJECT MATTER JURISDICTION
The United States hereby requests that this Court enter an order dismissing these ... have
advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject
matter jurisdiction.1 This Court lacks subject matter jurisdiction over the Petition because
See, e.g., Gntpo ... nder Rule 12(h)(3), Fed.R.Civ.P., the defense of lack of subject matter jurisdiction may be
raised at any time by motion of a party or otherwise."); see also
https://www.justice.gov/epstein/files/DataSet%209/EFTA00100337.pdf
EFTA01084083Set 9
2007-10-0472p23,940w
weakens when valuing a
minority or other ownership interest in a going concern which lacks the right to
liquidate assets or sell the business. Exceptions are when liquidation ... that there are no
income taxes at the Partnership level. Lastly, a discount for lack of marketability
was selected based on factors limiting the liquidity of a limited partnership interest ... Empire's opinion that the
appropriate way to account for a partnership's lack of tax at the partnership level
is to, first, value it as a C-Corp
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084083.pdf
EFTA00792500Set 9
2011-01-1869p16,292w
level-one offender instead. More
particularly, defendant contends that the level-three designation lacked the support of
clear and convincing evidence, and was based instead on improper considerations.
Defendant further ... opportunity to present evidence on disputed issues, and issued an order that
-4-
EFTA00792507
lacked the requisite findings and conclusions.
THE MATERIALS PROVIDED TO THE SORA COURT
The Florida Probable ... defendant's conduct while on Community Control
had been assessed as "satisfactory"; that he lacked a history of substance abuse; and
that, because defendant had pleaded guilty, he was being
https://www.justice.gov/epstein/files/DataSet%209/EFTA00792500.pdf
EFTA00602338Set 9
2011-01-1869p14,710w
level-one offender instead. More
particularly, defendant contends that the level-three designation lacked the support of
clear and convincing evidence, and was based instead on improper considerations.
Defendant further ... opportunity to present evidence on disputed issues, and issued an order that
-4-
EFTA00602345
lacked the requisite findings and conclusions.
THE MATERIALS PROVIDED TO THE SORA COURT
The Florida Probable ... defendant's conduct while on Community Control
had been assessed as "satisfactory"; that he lacked a history of substance abuse; and
that, because defendant had pleaded guilty, he was being
https://www.justice.gov/epstein/files/DataSet%209/EFTA00602338.pdf
EFTA00205154Set 9
2008-07-1119p3,384w
Petitioners,
vs.
UNITED STATES,
Respondent.
UNITED STATES' SEALED MOTION TO DISMISS
FOR LACK OF SUBJECT MATTER JURISDICTION
The United States hereby requests that this Court enter an order dismissing these ... have
advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject
matter jurisdiction.' This Court lacks subject matter jurisdiction over the Petition because ... nder Rule 12(hX3), Fed.R.Civ.P., the defense of lack of subject matter jurisdiction may be
raised at any time by motion of a party or otherwise."); see also
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205154.pdf
EFTA00208794Set 9
2008-07-1120p4,911w
Petitioners,
vs.
UNITED STATES,
Respondent.
UNITED STATES' SEALED MOTION TO DISMISS
FOR LACK OF SUBJECT MATTER JURISDICTION
The United States hereby requests that this Court enter an order dismissing these ... have
advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject
matter jurisdiction.' This Court lacks subject matter jurisdiction over the Petition because
See, e.g., Gnipo ... nder Rule 12(h)(3), Fed.R.Civ.P., the defense of lack of subject matter jurisdiction may be
raised at any time by motion of a party or otherwise."); see also
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208794.pdf
EFTA00209769Set 9
2008-07-1112p4,172w
JANE DOE #2,
Petitioners,
vs.
UNITED STATES,
Respondent.
UNITED STATES' MOTION TO DISMISS
FOR LACK OF SUBJECT MATTER JURISDICTION
The United States hereby requests that this Court enter an order ... have
advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject
matter jurisdiction.' This Court lacks subject matter jurisdiction over the Petition because
See, e.g., Grupo ... nder Rule 12(h)(3), Fed.R.Civ.P., the defense of lack of subject matter jurisdiction may be
raised at any time by motion of a party or otherwise."); see also
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209769.pdf
EFTA01101457Set 9
2014-11-11100p33,689w
Valuation Date: June 3, 2014
Page 12
control over the assets and lack of a ready market to dispose of or trade its assets
is considered in detail ... built-in gains tax costs are reflected in the consideration of the discounts for lack of
control and marketability.
EFTA01101474
Alan Halperin, Esq.
November 11, 2014
APO' GRAT ... rata ABV associated with
the Interest was calculated. Next, a combined discount for lack of control and lack
of marketability was applied to estimate the fair market value
https://www.justice.gov/epstein/files/DataSet%209/EFTA01101457.pdf
EFTA01724063Set 10
100p15,941w
Same objections,
14 argumentative, speculation, harassing,
15 assumes facts not in evidence and lacks
16 predicate.
17 A I asked her to
18
19 A I believe her own sworn ... harassing. It assumes
5 facts not in evidence. The question
6 continues to lack predicate, and I also
7 believe the question has been asked and
8 answered sometime ... compound. It is vague.
9 It assumes facts not in evidence and lacks
10 predicate.
11 A Though I would like to answer that
12 question with specificity and detail
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01724063.pdf
EFTA02698548Set 11
2011-05-1418p4,101w
International Monetary Fund ("IMF").
4. Denied.
5. Denied, except that Mr. Strauss-Kahn lacks knowledge or information sufficient
to form a belief as to the truth of the allegations contained ... allegations.
6. Denied.
EFTA_R1_02059167
EFTA02698548
7. Denied, except that Mr. Strauss-Kahn lacks knowledge or information sufficient
to form a belief as to the truth of the allegations ... Plaintiff's allegations have received worldwide
attention.
9. Denied, except that Mr. Strauss-Kahn lacks knowledge or information sufficient
to form a belief as to the truth of the allegations
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02698548.pdf