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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 32 of
document IMAGES-002-HOUSE_OVERSIGHT_014115.txt Feb 25, 2015 House Oversight Committee — Epstein Estate Records (Nov 2025)

…showitz “upon information and belief” is an example of prohibited “word play.” That qualification has no bearing on the Defendant’s discovery obligations. “Will Produce” The Rules of Civil Procedure require production and not just a commitment of production at some unspecified...

Plaintiffs assert claims under the Anti-Terrorism Act, 18 U.S.C. §§ 2331 ef seg., and under the Rack
document IMAGES-007-HOUSE_OVERSIGHT_023372.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

…risdiction applicable to each statute and pursuant to 28 U.S.C. § 1331. In some of the underlying cases, plaintiffs and defendants were diverse, in that defendants were citizens of foreign states or of states different from the states in which plaintiffs were citizens. Plaintiffs...

necessary to mount a significant transborder attack. See JA3777-78. In particular, plaintiffs allege
document IMAGES-007-HOUSE_OVERSIGHT_023399.txt Sep 11, 2001 House Oversight Committee — Epstein Estate Records (Nov 2025)

… resources, enabling it to grow rapidly into a formidable international terrorist network”). Imposing ATA liability on defendants who provide this crucial formative support for a terrorist organization is clearly consistent with Congress’ intent, see supra pp. 66-73, and consist...

Oh, Ms. Menninger reminds me, your Honor -- and I
document IMAGES-001-HOUSE_OVERSIGHT_011410.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…r reputation at issue, who is claiming emotional distress damages, and plaintiffs are in a much different position than defendants when it comes to cross-examinations about these issues, particularly in defamation cases, because as Ms. Menninger pointed out earlier, under Rule 4...

2007 Utah L. Rev. 861, *871
document IMAGES-004-HOUSE_OVERSIGHT_017643.txt Jan 26, 2007 House Oversight Committee — Epstein Estate Records (Nov 2025)

… beyond, the specific statutory provisions. The CVRA reflects a careful Congressional balance between the rights of the defendant, the discretion afforded to prosecution, and the new rights afforded to victims. In light of this careful statutory balance, [we] felt that it would n...

Re: Hello
email IMAGES-011-HOUSE_OVERSIGHT_031561.txt Jul 4, 2018 House Oversight Committee — Epstein Estate Records (Nov 2025)

… replaced Weissmann in the EDNY. He withheld evidence terribly in his cases, regularly threatened others, and accused a defendant of putting out a contract on him when he knew it was a completely bogus claim, but gave him the publicity he craved. He is 100% in the pro-Clinton, an...

just to make sure the limitations period runs on all his or her crimes while he or she remains
document IMAGES-010-HOUSE_OVERSIGHT_030208.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…e other hand, the regular processes of the federal criminal system might be a better forum for an alleged complex multi-defendant financial conspiracy including money laundering, bank fraud, tax evasion, etc. In short, context matters for a special counsel or other prosecutor con...

Because crime victims lack a right to appointed counsel, many victims
document IMAGES-002-HOUSE_OVERSIGHT_014052.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…ase to date to assess this question is the Fifth Circuit’s decision in In re Dean.’ There, a wealthy corporate criminal defendant reached a generous plea deal with the Government—a deal that the Government filed for approval with the district court without conferring with the vic...

name of it, but it was the plaintiff's motion, sort of omnibus
document IMAGES-001-HOUSE_OVERSIGHT_011392.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…The plaintiff wanted until 15 days before trial to make whatever showing they wanted. It would make sense -- well, in defendant's 404(b) motion, there are some of those issues, as well. We certainly could argue part of that. The Court may want to defer that to the entirety of...

come into evidence because they have been validated by an
document IMAGES-001-HOUSE_OVERSIGHT_011430.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…ess of the hearsay issue and the business records exception, again, as you said in your June 20th order, the point of defendant's knowledge at the time she mad a defamatory statement is very significant in this case, so if she knew ven if she didn't believe my client, if she...

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 13 of
document IMAGES-002-HOUSE_OVERSIGHT_014096.txt Mar 24, 2015 House Oversight Committee — Epstein Estate Records (Nov 2025)

…solve the discovery issues presented in this motion (and others) as evidenced by the letter attached as Exhibit B. The Defendant has failed to respond as of the time of the filing of this motion. HOUSE_OVERSIGHT_014096

Dershowitz that we would then believe, in light of your ruling
document IMAGES-001-HOUSE_OVERSIGHT_011342.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…stand. And one of the reasons we have not proposed a redacted joinder motion, that showed up in a reply brief from the defendant, we didn't move to file a surreply with a possible motion. We think the best way to proceed, and we're happy to get guidance from your Honor, but onc...

*35 The Leaders Of The Mwl And Iiro Similarly Ensconced Well Known Bin Laden Associates As Senior Officials Of Those Organizations
document *35 The leaders of the MWL and IIRO similarly ensconced well known bin Laden associates as senior officials of those organizations House Oversight Committee — Epstein Estate Records (Nov 2025)

thereby providing al-Qaeda with an efficient mechanism to support its global expansion. Defendant Abdullah Naseef met personally with Osama bin Laden around the time of Al-Qaeda’s formation

The Direct Involvement Of Appellee Aqeel And Al Buthe In Orchestrating Al Haramain’s Terrorist Activities Was Also Well Documented. As Defendant Aqeel Himself Stated
document The direct involvement of Appellee Aqeel and al-Buthe in orchestrating al Haramain’s terrorist activities was also well documented. As defendant Aqeel himself stated House Oversight Committee — Epstein Estate Records (Nov 2025)

“[t]he [al Haramain branch] offices’ directors are employees who follow directions of the main office with regards to hiring workers at the offices and making any decisions on cooperation with any party.”42 In designating Aqeel as a terrorist in 2005

For Each Defendant
document For each defendant House Oversight Committee — Epstein Estate Records (Nov 2025)

plaintiffs’ detailed allegations focused on the knowing or reckless nature of the provision of support to al-Qaeda. The particular allegations set forth below are in addition to plaintiffs’ extensive allegations regarding the broader context of al-Qaeda’s use and development of a...