Epstein Secrets

reasonably related to the original grand jury matter, will be handled by the district judge before whom the original matter was filed." Since Judge Middlebrooks issued the Order granting the government limited authority to disclose grand jury material, any issue regarding the scope of the Order should be ad

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, Vs. UNITED STATES, Respondent. RESPONDENT'S OPPOSITION TO PETITIONERS' MOTION REQUESTING AN ORDER DIRECTING THE GOVERNMENT TO

ARRA; (2) the service of filings containing the aforementioned grand jury information shall be limited to counsel for Petitioners Jane Doe No.1 and Jance Doe No. 2 and for the government in Case No. 08-80736-CIV-MARRA, and shall be accompanied by a copy of this Order; and (3) further dissemination by any

s. Under Florida law, there is no immunity for acts undertaken in judicial proceedings that bear no relation to those proceedings. See, e.g., Levin, Middlebrooks, Mahie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 616, 608 (1994). It is for a fact finder to determine whether Edwards' ac

perfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airplane travel in support of Jane Doe's Federal Rico claims and punitive damages (911 77-79); Epstein's interview with a New York newspaper reporter (9191 80-81); Epstein's alleged threat

policy, and/or a violation of First Amendment principles. Our filing the entire reply under seal is based upon the November 7, 2011 Order from Judge Middlebrooks, permitting the government to make limited disclosure of Grand Jury matter. Judge Middlebrooks permitted disclosure under three conditions, includi

hting us when all we want is to chance to give our position to Marra in a sur-reply?I I frankly don't understand that. Paul Cassell Co-counsel for Jane Doe #1 and Jane Doe #2 EFTA00205133 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the Univer

on to a motion for a short extension of time to comply with Judge Marra's order requiring us to file unredacted pleadings. Some of those have Judge Middlebrooks' sealed order attached and I need to file something with Judge Middlebrooks to avoid getting caught in the crosshairs. I am pretty sure that he is i

es compelling arguments that the Eleventh Circuit lacks jurisdiction, at this time, over any such appeal. Thanks! Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 3

Normal Yes. I may be overly optimistic, but I expect to have everything done by Monday (Tuesday at the latest), aside from waiting to address Judge Middlebrooks' sealed order. And I expect that we could finalize things fairly quickly after getting the ruling. 10 1111 111 1 uject: : xtensSme re r action I

involving criminal proceedings. We'd like to know quickly, because we are filing very soon in opposition to the motion to stay. > Paul and Brad for Jane Doe #1 and Jane Doe #2 > CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for th

for a short extension of time to comply with Judge Marra's order requiring us to file unredacted pleadings. Some of those have Judge EFTA00209823 Middlebrooks' sealed order attached and I need to file something with Judge Middlebrooks to avoid getting caught in the crosshairs. I am pretty sure that he is i

compelling arguments that the Eleventh Circuit lacks jurisdiction, at this time, over any such appeal. Thanks! > Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 > Paul G. Cassell > Ronald N. Boyce Presidential Professor of Criminal Law > S.J. Quinney College of Law at the University of U

: (USAFLS) Sent: Wednesday, May 31, 2017 6:18 PM To: (USAFLS) < >; Subject: Status? (USAFLS) Cla Hi and MI— I left a message for one of Judge Middlebrooks' clerks since I had not heard back from Judge Hurley's chambers today. I will keep you posted. I was supposed to be in a debriefing tomorrow mornin

nterviewed and had not necessarily determined were in fact victims of a federal offense or came under the protection of the CVRA. For example, when Jane Doe 1 and Jane Doe 2 were sent victim notification letters in August 2006, and when Jane Doe 1 was provided a victim notification letter on or about June

ed to the proceedings, the litigation privilege applied to both the abuse of process and malicious prosecution claims, and also finding that Levin, Middlebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994), Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla.

ge female plaintiff. To augment his concocted story, Rothstein invited D3 to his office to view the thirteen banker's boxes of actual case files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real. In particular, Rothstein cla

orney General, approved the request. (See Ex. 10.) I then applied to the Court for an Order compelling Jane Doe 2's testimony. U.S. District Judge Middlebrooks granted the Application on April 16, 2007. (Ex. 11.) II. After receiving Judge Middlebrooks' Order, Mr. Eisenberg then asked whether Jane Doe 2 c

9. On February 12, 2007, after another conversation where Mr. Eisenberg re-iterated Jane Doe 2's intent to invoke her Fifth Amendment privilege and Jane Doe's refusal to testify without 6001 immunity, at my request, Mr. Eisenberg provided a letter detailing Jane Doe 2's concerns regarding testifying witho

s. To avoid contravening the Orders of this Court and Judge Middlebrooks' Order, Respondent has determined that it must seek permission from Judge Middlebrooks to unseal or partially unseal his Order. 3. An additional seven (7) days is requested to prepare and receive a ruling on that motion. This request

VICE I hereby certify that a true and correct copy of the foregoing was served via CM/ECF this 28th day of June, 2013, upon Counsel for Petitioners Jane Doe #1 and Jane Doe #2. s/A. Marie Villafaiia A. Marie Villafalla Assistant United States Attorney SERVICE LIST Jane Does 1 and 2 v. United States,