EFTA01202344Set 9
2014-08-2134p10,281w
conflict with its mission, but also that its activities have been impeded. Pl.'s
Opp'n 25. Despite its lengthy regurgitation of allegations from the complaint, it fails ... have, such as a
complaint and a judicial assessment of the settlement. Pl.'s Opp'n 27-29. But even if the
settlement does not match Plaintiff's policy preferences ... Realty Corp. v. Coleman 455 U.S. 363 (1982), is therefore
misplaced. See Pl.'s Opp'n 24-25. In that case, the Supreme Court held that the defendant's
"racial
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EFTA00028880Set 8
2016-01-1123p6,182w
language provides, arguing that following the NPA's
plain language would contradict "common sense." (Opp.' 8, 16.) But a non-prosecution
agreement is not an ordinary contract. Federal prosecutors know ... includes Ms. Maxwell. As the opening statement of the Indictment makes clear: "The charges
"Opp." refers herein to the Government's Omnibus Opposition to the Defendant's Pre-Trial Motions ... evidence that
the parties intended to confer a benefit on her in particular." Opp. 20. In essence, the
government implausibly argues that even though the parties expressly agreed to immunize
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EFTA00076468Set 9
2018-06-1320p6,187w
answers provided, and
(4) communications between DFS and the government.
(Defs.' PRI Opp'n,2 at 8.)
Although these demands are narrower than those Defendants originally made in their
subpoenas ... letter motion to quash, dated March 2, 2018, ECF No. 258.
2 - Deis.' PRI Opp'n." refers to "Memorandum of Law in Opposition to Motions to Quash Subpoenas Served ... part of DFS's investigation into PRI. (Defs.' PRI Opp'n, at 8.) According to
Defendants, this DFS investigation "found that Bonomo cooked PRI's books 'and then tried
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EFTA00591577Set 9
2015-12-2813p3,821w
Plaintiff offers only who made the statement, a point not in dispute. Pl.'s
Opp'n at 22. As to whom, she alleges the statements were "widely disseminated ... media
and public." Pl.'s Opp'n at 22; Compl. 1 30. Twice this Court deemed similar pleadings
insufficient. Hawkins v. City ... standard is far more lenient for libel claims than for slander claims. Pl.'s
Opp'n at 24 (citing Liberman v. Gelstein, 80 N.Y.2d 429 (N.Y. 1992)). Not so. Rather
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EFTA00801525Set 9
2017-11-2219p4,773w
denied or retracted his statement to the Court.
4
EFTA00801531
FILED UNDER SEAL
motive." Opp. at 7. However, the Prior Proceedings did not involve allegations that Epstein
coerced or defrauded ... strongest retort is to assert that the Prior Proceedings provide
"contextually necessary facts." Opp. at 6, 8. But the Prior Proceedings provide no context for
Plaintiff's baseless claim that ... cover-up" involving attempts to "intimidate witnesses" and the "destruction of
documents and evidence." Opp. at 8. However, Plaintiff does not allege which Defendants
engaged in this conduct, specifically when
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EFTA00028903Set 8
2021-01-1122p6,173w
Superseding Indictment as Time-Barred
("Motion").
As the government agrees in its opposition ("Opp."), the four Mann Act counts against
Ms. Maxwell are timely only if the 2003 amendment ... dispute that Landgraf is the appropriate framework for
determining whether a statute applies retroactively. Opp. 27. Under Landgraf, the first step is
"to determine whether Congress has expressly prescribed ... abuse
victims who come forward or identify their abusers after a delay." See Opp. 31. But statutory
amendments, by nature, are designed to remedy perceived deficiencies in existing
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EFTA02725304Set 11
2012-12-3159p5,960w
DESCRIPTION 2007 2008 2009 2010 2011 2012
Partnership Distributions
Apollo Credit Opp Fund I $ 54,785,356 $ 8,405,145 $ 25,921,685 $ 72,572,319 161,684,505
Black ... Commercial Paper
Total Redemptions $ 9.922.488.447.60 $9.922.488.447.60 $ 0.00
Returns of Principal
08/31/2008 Apollo Credit Opp Fund I $ 4,001,054.00 $ 4,001,054.00 $ 0.00
Return of Capital
Total Returns of Principal ... 04/30/2008 4,700,000 Par Purchased 4,700,000.00
Apollo Credit Opp Fund I
04/30/2008 Purchased 75,150,000.00
06/30/2008 Purchased 593,443.00
08/31/2008 Purchased 7,114,069.00
10/31/2008 Purchased
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02725304.pdf
EFTA01075600Set 9
2022-12-3159p5,912w
DESCRIPTION 2007 2008 2009 2010 2011 2012
Partnership Distributions
Apollo Credit Opp Fund ... Commercial Paper
Total Redemptions $ 9.922.488.447.6Q S9.922.488.447.60 $ 0.00
Returns of Principal
08/31/2008 Apollo Credit Opp Fund I $ 4,001,054.00 $ 4,001,054.00 $ 0.00
Return of Capital
Total Returns ... 04/30/2008 4,700,000 Par Purchased 4,700,000.00
Apollo Credit Opp Fund I
04/30/2008 Purchased 75,150,000.00
06/30/2008 Purchased 593,443.00
08/31/2008 Purchased 7,114,069.00
10/31/2008 Purchased
https://www.justice.gov/epstein/files/DataSet%209/EFTA01075600.pdf
EFTA01433450Set 10
2015-05-2716p7,433w
amount of $10 million [the "1999 Note"]. (Pis.' Mem. Of Law
in Opp'n to Mot. To Dismiss, Epstein Decl. ¶ 15; Mem. Of Law in Support of
Defs ... that the AIG
Investment was "suddenly and rapidly deteriorating." (Pls.' Mem. Of Law in
Opp'n to Mot. To Dismiss, Epstein Decl. ¶ 20.) According to the plaintiffs,
FTC's advisors ... information
from Chase Manhattan, the Trustee of the fund. (Pls.' Mem. Of Law in Opp'n
to Mot. To Dismiss, Schantz Decl. ¶¶ 6-8. ) Chase Manhattan, however,
referred the plaintiffs
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EFTA01207793Set 9
22p17,194w
motion, Gov't's
government's unfettered right to search cargo at the Opp. to Defs.' Mot. [Dkt. # 37] ("Gov't Opp."); Defs.'
WestlawNext © 2015 Thomson Reuters. No claim ... initiated at the determination of whether the officer had reasonable
border. Gov't Opp. at 6, citing, inter alia, United States v. suspicion must be based upon the totality ... others); United States v. Tiong, 224 F.3d
4/8 Tr. at 86; Gov't Opp. at 10, n.9, II n.11. 1136, 1140 (9th Cir.2000).
*9 In Cotterman, the Ninth Circuit announced
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EFTA01726507Set 10
1999-08-0237p7,942w
amount of $10 million [the "1999 Note"]. (Pls.'
Mem. Of Law in Opp'n to Mot. To Dismiss, Epstein Dec).. 5 15; Mem.
Of Law in Support of Defs ... that the AIG Investment was "suddenly and rapidly deteriorating."
(Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss, Epstein Decl. 1
20.) According to the plaintiffs ... information from Chase Manhattan, the Trustee of the
fund. (Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss, Schantz
Decl. ff 6-8. ) Chase Manhattan, however, referred
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EFTA01218059Set 9
2015-06-2119p2,549w
Sender:
Participants: ( ), Self ( jeeitunes®gmail.com )
Then it becomes credit (here's MasterCard opp?) and commerce (here's alibaba opp?)
All about trust and it's there just not digital.
EFTA01218068 ... Sender:
Participants: ( ), Self ( e:jeeitunes@gmail.com )
Then it becomes credit (here's MasterCard opp?) and commerce (here's alibaba opp?)
All about trust and it's there just not digital ... Sender:
Participants: ( ), Self ( jeeitunes®gmail.com )
Then it becomes credit (here"s MasterCard opp?) and commerce (here"s alibaba opp?)
All about trust and it"s there just not digital
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EFTA00104521Set 9
2020-07-1412p3,749w
opposed the Defendant's motion on March 9,2021. Dkt.
No. 165 ("Gov't Opp'n"). The Defendant filed her reply under temporary seal on March 16,
2021.
II. Legal ... third bail motion while Defendant's bail appeal is pending. See Gov't
Opp'n at 2-3; Reply at 2-3; see also United States v. Rodgers, 101 F.3d ... relevance and practical impact of the renunciations is, at best, unclear.
See Gov't Opp'n at 5. With respect to her offer to renounce her French citizenship, the Court
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