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identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe
ations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Office"). They also falsely allege that Movant, while still employed by the Office engaged in improper conduct relating to Epstein. The Motio
dentiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe t
between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney's Office was also investigating 4 EFTA00229920 rann97,""-^ Cas
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe tha
between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney's Office was also investigating 4 08-80736-CV-MARRA 000674 EFTA
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan ! DaintlerChrysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could beli
ations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Office"). They also falsely allege that Movant, while still employed by the Office engaged in improper conduct relating to Epstein. The Motio
Entities connected to both Kaplan and Office for the Southern District of Florida

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATIONFBI
ORGANIZATIONJane Doe
PERSON
Scarlett Johansson
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Lesley Groff
PERSON
Alexander Acosta
PERSON
Virginia Giuffre
PERSON
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
Donald Trump
PERSONMaria Farmer
PERSONJack Goldberger
PERSON