Epstein Secrets

301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: [email protected] and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected]

Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction. The Court should deny the motion. Because the Government has filed a motion to dismiss alleging that the victims' pleadings are facially deficient

rt, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates. LLC Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney College of Law at the Universit of Utah Salt Lake City, Utah 84112 Attorneys for Jane Doe # 1 and Jane Doe # 2 EFTA00208793

ing such information be filed under seal. EFTA00208791 WHEREFORE, the United States respectfully requests that the Motion to Dismiss for lack of Subject Matter Jurisdiction be sealed. DATED: November 7, 2011 Respectfully submitted, WIFREDO A. FERRER The undersigned hereby certifies and affirms that a copy of the fore

s, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [Service via CM/ECF] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 [Service via CM/ECM Attorneys for Jane Doe # 1 and Jane Doe # 2 7 EFTA0060

the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel

N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [email protected] 954-524-2820 Fax: 954-524-2822 [Service via CM/ECF) Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] [Service v

the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel