Epstein Secrets

ct matter of dropping and adding parties." Id at 873 (citation omitted). See also Galustian I. Peter, 591 F.3d 724, 730 (4th Cir. 2010), and Frank'. U.S. West, Inc., 3 F.3d 1357, 1365-66 (10'h Cir. 1993) ("To the extent that Plaintiffs' motion to supplement sought the addition of a party, it is controlled by Ru

ered on FLSD Docket 02/23/2015 Page 1 of 25 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 OF AMERICA, Respondent. RESPONDENT'S OPPOSITION TO JANE DOE NO. 1 AND JANE DOE NO. 2's PROTECTIVE MOTION PUR

torola, Schaumburg, IL, June 17-18, 1997 Sears Canada, Toronto, Ontario, Canada, July 14-15, 1997 Levi Strauss, San Francisco, CA, August 12, 1997 U.S. West, Inc., Denver, CO, August 21, 1997 EFTA00073029 Park Dietz, M.D., M.P.H., Ph.D. Page 84 Federated Dept. Stores, San Francisco, CA, August 25-26, 1997

k, New York) [2nd Circuit Opinion: 938 F.2d 1535 (2nd Cir. 1991)] Testified at deposition, 5/13/90 Testified in court (trial or hearing), 5/14/90 Jane Doe v. Stuart Brown. M.D. (San Diego, California) Testified by deposition, 6/6/90 Carin Evans vs. Richard Benton, Ph.D. (Houston, Texas) Testified at

to trial. She was just 15 years old when she was drawn into Epstein’s exploitative world in 1998. In her civil writ against him, under the pseudonym Jane Doe 102’ she alleged that her duties included being ‘sexually exploited by Epstein’s adult male peers including royalty’. Now, horrified by the evidence

v. Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies to amendments seeking to add parties); Frank v. U.S. West, Inc., 3 F.3d 1357, 1365 (10th Cir. 1993) (“A motion to add a party 1s governed by Fed. R. Civ. P. 15a)... .”). Rule 21, “Misjoinder and Non-joinder of P

v. Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies to amendments seeking to add parties); Frank v. U.S. West, Inc., 3 F.3d 1357, 1365 (10th Cir. 1993) (“A motion to add a party is governed by Fed. R. Civ. P. 15(a)....”). Rule 21, “Misjoinder and Non-joinder of P

e proposed amendment itself, in which all four victims simply allege the same general facts.”)). As the Does argue at length in their Rule 15 Motion, Jane Doe 1’s original petition “specifically allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims.