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TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottinger LP 425 North Andrews Avenue, Suite
Page: EFTA00021442 →ed, the Eleventh Circuit has clearly held that the manner in which an agreement is formed can render an otherwise-valid agreement unenforceable. In San Pedro v. United States, 79 F.3d 1065 (11th Cir. 1996), the Eleventh Circuit held that in order for any provision in a plea agreement to be enforceable, "t
Page: EFTA00021467 →of all relevant circumstances, it is important to understand the very limited reference the victims made to Epstein's NPA in their civil lawsuits. Jane Doe I and 2 filed their civil lawsuits in about September 2008, only after their CVRA petition had been filed — and had succeeded in forcing the USAO- SDF
Page: EFTA00021493 →TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice T
Page: EFTA00022546 →ed, the Eleventh Circuit has clearly held that the manner in which an agreement is formed can render an otherwise-valid agreement unenforceable. In San Pedro v. United States, 79 F.3d 1065 (11th Cir. 1996), the Eleventh Circuit held that in order for any provision in a plea agreement to be enforceable, "t
Page: EFTA00022571 →v-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 27 of 70 United States Attorney and the AUSAs who negotiated the plea agreement with San Pedro did not have the authority to promise that he would not be deported." Id. at 1072. So too here. Prosecutors were simply not authorized to offer Eps
Page: EFTA00022572 →ntered on FLSD Docket 07/24/2019 Page 1 of 5 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. JEFFREY EPSTEIN, Limited Intervenor. LIMITED INTERVENOR JEFFREY EPSTEIN'S MOTION FOR
Page: EFTA00021512 →h amendment right — not an alleged victim's — to insist that the defendant be represented by conflict-free counsel; c) rely heavily on the case of San Pedro v. United States, 79 f.3d 1065, 1068 (11" Cir. 1999) (DE 466:24-25, 38), an easily distinguished case not cited by Petitioners in their initial sub
Page: EFTA00021513 →Entities connected to both San Pedro and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Donald Trump
PERSON
the University of Utah
ORGANIZATION
Jeffrey Sloman
PERSON
Marc Rich
PERSONthe Eleventh Circuit
ORGANIZATION
Julie K. Brown
PERSON
Alfredo Rodriguez
PERSON
Supreme Court
ORGANIZATION
George Mitchell
PERSON
Woody Allen
PERSON