EFTA01080086Set 9
2008-07-07134p35,216w
went so
ms the exis tenc e of this sign ed non-prosecution agreement. Indeed, the
the victi
rming them
send (in Janu ary 2008 ) a false victi m notification ... agreement —
the non-prosecution agreement would
ut the agreement would
confidentiality provision. Indeed, even notifying the victims abo
at least
. Accordi ngly, from September 24, 2007 through
presumably have violated ... arranged for this failure to notify the
failure to notify the victims and, indeed,
10
EFTA01080101
Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA01080086.pdf
EFTA00076303Set 9
2019-07-1228p13,938w
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 5
Indeed, while the defendant has still not filled out a financial affidavit, under penalty of
perjury ... there is absolutely nothing in the defendant's minimal financial submission to verify that.
Indeed, and as discussed further below, even assuming the defendant's assets are presently ... strength of
the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence,
already robust less than a week ago when the Indictment was unsealed, is growing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076303.pdf
EFTA00105478Set 9
2019-07-1228p13,950w
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 5
Indeed, while the defendant has still not filled out a financial affidavit, under penalty of
perjury ... there is absolutely nothing in the defendant's minimal financial submission to verify that.
Indeed, and as discussed further below, even assuming the defendant's assets are presently ... strength of
the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence,
already robust less than a week ago when the Indictment was unsealed, is growing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105478.pdf
EFTA00100380Set 9
2019-07-1228p13,944w
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 5
Indeed, while the defendant has still not filled out a financial affidavit, under penalty of
perjury ... there is absolutely nothing in the defendant's minimal financial submission to verify that.
Indeed, and as discussed further below, even assuming the defendant's assets are presently ... strength of
the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence,
already robust less than a week ago when the Indictment was unsealed, is growing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00100380.pdf
EFTA01295633Set 10
2015-10-01135p75,076w
statistical study unreliable in establishing a
question of discrimination common to the class. Indeed, to conclude otherwise would
undermine prior precedent, rendering plaintiffs unable to bring a statistics-based
employment ... analysis makes assumptions based on imperfect
data, but whether those assumptions are reasonable. Indeed, statistics are not certainties
but are merely a body of methods for making wise decisions ... significance is not always synonymous with legal significance, such as in
the discrimination context. Indeed, the usefulness of statistical evidence often depends on
all of the surrounding facts and circumstances
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01295633.pdf
EFTA00798121Set 9
46p9,818w
made without evidentiary basis and without articulating
findings of fact and conclusions of law. Indeed, the People improperly
attempt to bolster their newfound alignment with the hearing court by
offering ... right were asserted." Shondel v. Mark D., 7 N.Y.3d 320, 326 (N.Y.
2006). Indeed, courts have invoked the doctrine of estoppel against
government entities when not doing so would result ... Board
materials. See A.82-A.96, generally; see also Email of Dec. 10, 2010.
Indeed, but for the People's agreement to advocate for a Level 1
adjudication on consent, Appellant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00798121.pdf
EFTA01085713Set 9
51p10,619w
made without evidentiary basis and without articulating
findings of fact and conclusions of law. Indeed, the People improperly
attempt to bolster their newfound alignment with the hearing court by
offering ... right were asserted." Shondel v. Mark D., 7 N.Y.3d 320, 326 (N.Y.
2006). Indeed, courts have invoked the doctrine of estoppel against
government entities when not doing so would result ... Board
materials. See A.82-A.96, generally; see also Email of Dec. 10, 2010.
Indeed, but for the People's agreement to advocate for a Level 1
adjudication on consent, Appellant
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085713.pdf
EFTA00285477Set 9
2017-05-1514p6,372w
fraudulent statements" that
Epstein o. are each alleged to have made to Plaintiff. Indeed, the Complaint only alleges
that Epstein "confirmed" this representation, that 'confumed this promise to Plaintiff
many ... identify with particularity that Epstein anawere the
speakers of these alleged fraudulent statements. Indeed, the Complaint only alleges that Epstein
and "confirmed" the statements, not that they made the statements ... allege who actusll made the alleged statement that was allegedly confirmed
by the Defendants. Indeed, as to there is no allegation that she ever spoke to or met with
Plaintiff
https://www.justice.gov/epstein/files/DataSet%209/EFTA00285477.pdf
EFTA00211718Set 9
2007-04-2432p10,140w
have controverted those facts in the accompanying Response to Petitioners' Statement of
Uncontroverted Facts. Indeed, many of the so-called "facts" are legal conclusions or argument
of petitioners' counsel ... right to confer did not arise until a formal criminal
charge had been filed. Indeed, it makes no sense to conclude that conferring about an NPA is
required where notification ... demonstrates it wanted to close a gap in the statute.
Indeed, the legislative history of the amendment demonstrates that the provision sought to add to
and strengthen the existing rights
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211718.pdf
EFTA00584101Set 9
32p6,747w
made without evidentiary basis and
without articulating findings of fact and conclusions of law. Indeed, the
People improperly attempt to bolster their newfound alignment with
the hearing court by offering ... right were asserted." Shondel v. Mark D., 7 3d 320, 326 M.
2006). Indeed, courts have invoked the doctrine of estoppel against
government entities when not doing so would result ... reflected in
the police reports upon which the Board based its recommendation. A.95 (Pr.).
Indeed, Appellant went so far as to alert the hearing court that significant
additional evidence
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584101.pdf
EFTA01071961Set 9
2013-08-3071p17,109w
correspondence, either under Fed. R. Evid.
410 or a "common law" privilege. Indeed, Epstein goes so far as to argue that the
District Court's decision somehow "dramatically reshapes ... reaching the secret non-prosecution agreement is the central element
of the case. Indeed, the only thing that is unprecedented about this case is the fact
that Epstein and prosecutors ... were not general discussions of leniency, the victims would
simply respond that this is indeed in question — because the District Court has
specifically made a factual finding to the contrary
https://www.justice.gov/epstein/files/DataSet%209/EFTA01071961.pdf
EFTA01077101Set 9
61p12,214w
Court made its risk assessment
determination based on allegations that did not -- and indeed could not,
as a matter of law -- constitute clear and convincing evidence. Such a
determination ... Registration Act: Risk Assessment Guidelines
and Commentary, Commentary (2006), at 5, ¶ 7 (emphasis added).
Indeed, in deciding how to evaluate allegations outside of the crime of
22
EFTA01077129
conviction ... Board "obviously took [their own guidelines] into consideration" when
assessing points for uncharged conduct). Indeed, although the Court
cited no specific information to suggest that the Board itself
communicated with
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077101.pdf
EFTA01098878Set 9
2005-11-2042p34,835w
than
participants. Hence, we predicted that undoing that inhibition only some of its properties. Indeed, it is difficult to ignore irrele-
(switching back to making a dominant response) should exact ... demands minimized] is also consistent with this predic-
conditions of the Dots task tion). Indeed, accuracy differences between these two conditions
must continue to decrease after 13 years ... younger the children.
that the Dots-Incongruent block would be more difficult than Indeed, performance differences between the Dots-Incongruent
Dots-Congruent Block, but more important, that the difference
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098878.pdf
EFTA01085680Set 9
33p6,959w
right were asserted."
Shondel v. Mark D., 7 N.Y.3d 320, 326 (N.Y. 2006). Indeed, courts have
invoked the doctrine of estoppel against government entities when not
doing so would result ... behalf because
the People assured Appellant that they would not -- and indeed, could
not -- present evidence to support a Level 3 risk assessment.
As set forth in greater detail ... reflected in
the police reports upon which the Board based its recommendation. A.95 ('Pr.).
Indeed, Appellant went so far as to alert the hearing court that significant
additional evidence
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085680.pdf
EFTA00603264Set 9
2010-08-1657p11,344w
Court made its risk assessment
determination based on allegations that did not -- and indeed could not,
as a matter of law -- constitute clear and convincing evidence. Such a
determination ... Registration Act: Risk Assessment Guidelines
and Commentary, Commentary (2006), at 5, ¶ 7 (emphasis added).
Indeed, in deciding how to evaluate allegations outside of the crime of
conviction, the SORA guidelines ... Board "obviously took [their own guidelines] into
consideration" when assessing points for uncharged conduct). Indeed,
although the Court cited no specific information to suggest that the
Board itself communicated with
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603264.pdf
EFTA00214291Set 9
2007-12-1135p16,114w
large and small, renders Jeffreys mutter
entirely sal genesis. We say this not lightly. Indeed, as you will glean from our two letters. we
are gravely concerned that, in addition ... Witness Statements Establish That Mr. Epstein Ilid Not Tame
Masseuses Under IS.
Indeed, the witness slaleincots demonstrate that Mc opposite is
rw hat the many of ‘•• • •
VC%
and
visit ... decision. of one count of the solicitation of
prostitution, was hardly irrational or irregular. Indeed, I ana Belohlavek. a Florida sex
prosecutor for 13 years, concluded that the women
https://www.justice.gov/epstein/files/DataSet%209/EFTA00214291.pdf
EFTA00792569Set 9
39p7,774w
right
were asserted." Shondel v. Mark D., 7 N.Y.3d 320, 326 (2006). Indeed,
courts have invoked the doctrine of estoppel against government
entities when not doing so would result ... Appellant's
counsel.
8
EFTA00792581
the People assured Appellant that they would not — and indeed, could
not — present evidence to support a Level 3 risk assessment.
The People also contend ... police reports upon which the Board based its recommendation. See A.95 ('Pr.).
Indeed, Appellant went so far as to alert the hearing court that significant
additional evidence had been presented
https://www.justice.gov/epstein/files/DataSet%209/EFTA00792569.pdf
EFTA00314490Set 9
2009-12-0430p9,885w
Bear Stearns and Eptsein" (Am. St. Claim 119), others regularly served in that capacity. Indeed,
in a publicly-filed Complaint in a separate action in the United States District Court ... Bear Steams did
not involve investor contact or portfolio management, this infrequency is unsurprising. Indeed,
during the time Epstein claims to have been relying on Spector for investment advice,; Spector ... Funds" nor
represented that he oversaw the Funds. Am. St. Claim 1 16. Indeed, Epstein admits as much,
conceding that Ralph Cioffi and Matthew Tannin — not Spector — were
https://www.justice.gov/epstein/files/DataSet%209/EFTA00314490.pdf
EFTA02030825Set 10
2012-03-2140p10,008w
exploit them) to promote U.S. interests almost always win out
and trump domestic lobbies.
Indeed, when it counts and national interests demand it,
presidents who know what they're doing ... only actor in the U.S. system that can guide and
lead the country abroad. Indeed, the power of the pro-Israel
community recedes the farther away you get from Capitol ... they don't already want to go. Here is
where adult supervision is essential. Indeed, it's ultimately the
responsibility of the president to sort through these views and
determine
https://www.justice.gov/epstein/files/DataSet%2010/EFTA02030825.pdf
EFTA00625129Set 9
335p135,307w
three main reasons. Firstly,
I didn't understand the detailed mathematics, or indeed have a strong feel for the generalised
Lotka-Volterra model. Secondly, my computer programming, and modelling skills ... modelling in the way that most physicists, engineers and mathematical modellers use
dynamic modelling.
Indeed the macroeconomic model in this paper shares many ideas with, and certainly the
approaches ... finance or heterodox
economics, areas which are not usually well known to physicists, or indeed many economists.
These ideas include recent research in market microstructure, liquidity, post-Keynesian pricing
theory
https://www.justice.gov/epstein/files/DataSet%209/EFTA00625129.pdf