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Entered on FLSD Docket 03/05:2010 Page 21 of 36 Jane Doe v. Epstein Case No. 08-CV-80893-Marra-Johnson Page 21 double force. See, e.g., Duncan v. Walker, 533 U.S. 167, 174 (2001). The "legal disability" language in § 2255(b) should be interpreted to reference classic legal disabilities like insanity
ages in order to property preserve all issues pertaining to the proper application of §2255 for appeal. See C.MA. v. Epstein, Case No. 08-CIV-80811 Marra/Johnson; and Jane Doe II v. Epstein, Case No. 09-CW-80489 Marra/Johnson. EFTA00207698 Case 9:08-cv-80893-KAM Document 128 Entered on FLSD Docket 03 05 20
would be in the best interests of the parties and the public, inasmuch as it would avoid needless expense and conserve precious judicial resources. Walker v. Atlantic Coast Line Railroad Co., 121 So. 2d 713 (Fla. 1st DCA 1960). As explained below, the undisputed and incontrovertible facts establish tha
ds already had been prosecuting against Epstein on behalf of that same plaintiff for the better part of a year. See LM v. Jeffrey Epstein, 09-81092 Marra/Johnson; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22. The federal complaint, signed by Edwards, himself, was filed in federal cou
. When other plea arrangements have been negotiated in violation of federal law, they have been stricken by the courts. For example, United States' Walker, 98 F.3d 944 (7th Cir. 1996), held that where a sentence on a new crime could not run concurrently with a probation revocation the defendant was th
egations in depositions and other court filings. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 EFTA00177092 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 43 of 54 Petitioners' allegations pro
Entities connected to both Walker and Marra/Johnson

Jeffrey Epstein
PERSON
United States
LOCATION
Scarlett Johansson
PERSONJane Doe
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Marc Rich
PERSON
Supreme Court
ORGANIZATION
Donald Trump
PERSONMaria Farmer
PERSON
Joe Biden
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON