From: ' To: ' (USAEO)" ci [=. (USAFLS)" cci Subject: RE: Draft Opposition to Victims' Motion for Finding of Violations Date: Mon, 04 Apr 2011 17:21:09 +0000 Importance: Normal Hi, I've been holding off on reading the drafts, because it sounded like you guys are working on a new one. Is that what I should be doing? Or should I go ahead and read the two versions? From: Sent: Sunda To: Cc: Subject: RE: (USAFLS) April 03, 2011 2:40 PM USAFLS . (SMO); .(USAFLS); (USAFLS); (USAFLS); (USAEO); (USAEO) Draft Opposition to Victims' Motion for Finding of Violations Good afternoon, everyone. Here is my attempt at addressing the same topics. I will work with Dexter tomorrow to meld the two into one. « File: Response to Summary Judgment Motn 4-3-2011.wpd » One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts.") First I would hammer the fact that they told the court that there was no need for any more facts at the last hearing on this case. Then, I would not agree to many of their "facts" that Dexter has listed as admitted. In my start of a draft response to DE 49, which I have sent to Dexter, I included the following: We note the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar guidance. For example, there has been no civil or criminal finding by any judge or jury that: defendant Jeffrey Epstein (a billionaire with significant with significant political connections) sexually abused more than 30 minor girls at his mansion in West Palm Beach (sic), Florida, and elsewhere. Epstein performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to)