Epstein Secrets

-CY-80119-Marra-Johnson Page 14 majority of the Circuits that restitution under the 1996 MYRA was an incre

testimony, she was brought by another minor girl (Jane Doe No. 3) to EPSTEIN's Palm Beach home the one time

3 The Court in Financial Federation Title & Trust noted that the standard in the Eleventh Circuit is “more narrow and less subjective” than in other Circuits where a multi-factor test is used. Id. at 837. Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 4 of 9 - 5 -

filed an identical Motion to Stay in the case Jane Doe v. Epstein, case no. 08- CIV 80893 MARRA/JOHNSON. Plaintiffs concur in the arguments made by Jane Doe’s counsel in that case in opposition to Defendant’s Motion. (Case no. 08-CIV 80893, DE 31). The same reasoning and arguments apply in the instant ca

3 The Court in Financial Federation Title & Trust noted that the standard in the Eleventh Circuit is “more narrow and less subjective” than in other Circuits where a multi-factor test is used. Id. at 837. Case 9:08-cv-80119-KAM Document 82 Entered on FLSD Docket 04/23/2009 Page 4 of 9 - 5 -

filed an identical Motion to Stay in the case Jane Doe v. Epstein, case no. 08- CIV 80893 MARRA/JOHNSON. Plaintiffs concur in the arguments made by Jane Doe’s counsel in that case in opposition to Defendant’s Motion. (Case no. 08-CIV 80893, DE 31). The same reasoning and arguments apply in the instant ca

the "Application"), in connection with the matter Jane Doe 43 v. Epstein, et aL ("Jane Doe"), 17 Civ. 616 (

inion itself, as described above, but would risk rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a