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various standing orders, if not in this 7 case, in various other cases, that 8 specifically describe the protections of the 9 Fifth Amendment. Federal Courts have 10 ordered that certain questions that you are 11 asking shall not be answered or Mr. Epstein 12 would risk losing his Fifth Amendment 13
t I must assert those rights or risk 3 losing my attorneys. 4 5 6 Q Sure, let's test that answer. A Okay. Q Let's talk about Jane Doe 102, Jane Doe 7 102, , who was represented by 8 s firm, had nothing to do with 9 Rothstein, Rosenfeld, Adler. Do you know 10 A Who? 11 12 A Can you spel
2 this moment I must assert those rights or risk 3 losing my attorneys. 4 5 6 Q Sure, let's test that answer. A Okay. Q Let's talk about Jane Doe 102, Jane Doe 7 102, , who was represented by 8 s firm, had nothing to do with 9 Rothstein, Rosenfeld, Adler. Do you know 10 A Who? 11 12
request filed within the context of an ongoing judicial proceeding, not a vehicle for launching a new and freestanding piece of litigation. 171 Federal Courts 4- Mandamus While a petition for a writ of mandamus is an original application to the Court of Appeals, the writ is not an independent grant of ap
red the girls for Epstein's sexual gratification or participated in the sexual abuse themselves. The victims include the petitioners in this case, Jane Doe 1 and Jane Doe 2, who were 15 years old when first sexually abused by Epstein. B. Aug. 2006 Letter to Crime Victim about CVRA Rights Throughout the
her statutory rights under the CVRA. For example, in 2006 and before an indictment was drafted in 2007, the U.S. Attorney's Office told petitioner Jane Doe 2 in a letter that she had statutory rights "to confer with the attorney for the Government in the case," "to be treated with fairness," and to petit
various standing orders, if not in this 7 case, in various other cases, that 8 specifically describe the protections of the 9 Fifth Amendment. Federal Courts have 10 ordered that certain questions that you are 11 asking shall not be answered or Mr. Epstein 12 would risk losing his Fifth Amendment 13
t I must assert those rights or risk 3 losing my attorneys. 4 Q Sure, let's test that answer. 5 A Okay. 6 Q Let's talk about Jane Doe 102, Jane Doe 7 102, , who was represented by III 8 firm, had nothing to do with 9 Do you know 10 A Who? 11 12 A Can you spell it? 13 Q Common spelli
2 this moment I must assert those rights or risk 3 losing my attorneys. 4 Q Sure, let's test that answer. 5 A Okay. 6 Q Let's talk about Jane Doe 102, Jane Doe 7 102, , who was represented by III 8 firm, had nothing to do with 9 Do you know 10 A Who? 11 12 A Can you spell it? 13
gotiations were not protected from disclosure by any common-law priv- ilege. Affirmed. West Headnotes (1] Federal Courts 170E E..t.. 3581(1) 170B Federal Courts 170BXVII Courts of Appeals 170BXVII(K) Scope and Extent of Review 170BXVII(K)2 Standard of Review 170Bk3576 Procedural Matters 170Bk3581 Jurisdi
Pagel 749 F.3d 999, 24 Fla. L. Weekly Fed. C 1270 (Cite as: 749 F.3d 999) H United States Court of Appeals, Eleventh Circuit. Jane DOE NO. 1, Jane Doe No. 2, Plaintiffs-Appellees, 1. UNITED STATES of America, Defendant. Roy Black, Martin G. Weinberg, Jeffrey Epstein, Intervenors-Appellants. No.
rsity jurisdiction, which requires complete diversity of citizenship." Henderson'. Washington Nat. Ins. Co., 454 F.3d 1278, 1281 (11th Cir. 2006). Federal Courts are obligated to construe removal statutes very strictly, and "all doubts about jurisdiction should be resolved in favor of remand to state court."
1 Entered on FLSD Docket 08)18:2008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a, JANE DOE NO. I, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. MOTION TO REMAND Plaintiff Jane Doe moves the Court to remand this act
rsity jurisdiction, which requires complete diversity of citizenship." Henderson'. Washington Nat. Ins. Co., 454 F.3d 1278, 1281 (1Ith Cir. 2006). Federal Courts are obligated to construe removal statutes very strictly, and "all doubts about jurisdiction should be resolved in favor of remand to state court."
led by Jeffrey Epstein. (Tein, Michael) (Entered: 09/05/2008) 09/15/2008 22 r 3" KB REPLY to Response to Motion re 11 MOTION to Remand filed by Jane Doe. (Kuvin, Spencer) (Entered: 09/15/2008) 09/16/2008 21 r 893 KB NOTICE of Substitution of Counsel by Theodore Jon Leopold on behalf ofJane Doe (
report on November 28, 2018, U.S. Senator Ben Sasse, Chairman of the Senate Judiciary Subcommittee on Oversight, Agency Action, Federal Rights and Federal Courts, sent a December 3, 2018 letter to OPR, citing the Miami Herald's report and requesting that OPR "open an investigation into the instances identifie
S.C. Section 3771, Doe v. United States, Case No. 9:08-cv-80736-1CAM (S.D. Fla. July 7, 2008). Mother victim subsequently joined the litigation as "Jane Doe 2." ii EFTA01726259 Soon after he was incarcerated, Epstein applied for the Palm Beach County Sheriff's work release program, and the Sheriff appr
report on November 28, 2018, U.S. Senator Ben Sasse, Chairman of the Senate Judiciary Subcommittee on Oversight, Agency Action, Federal Rights and Federal Courts, sent a December 3, 2018 letter to OPR, citing the Miami Herald's report and requesting that OPR "open an investigation into the instances identifie
.C. Section 3771, Doe v. United States, Case No. 9:08-cv-80736-1CAM (S.D. Fla. July 7, 2008). Another victim subsequently joined the litigation as "Jane Doe 2." EFTA00095561 Soon after he was incarcerated, Epstein applied for the Palm Beach County Sheriff's work release program, and the Sheriff approved
report on November 28, 2018, U.S. Senator Ben Sasse, Chairman of the Senate Judiciary Subcommittee on Oversight, Agency Action, Federal Rights and Federal Courts, sent a December 3, 2018 letter to OPR, citing the Miami Herald's report and requesting that OPR "open an investigation into the instances identifie
.C. Section 3771, Doe v. United States, Case No. 9:08-cv-80736-1CAM (S.D. Fla. July 7, 2008). Another victim subsequently joined the litigation as "Jane Doe 2." EFTA00095730 Soon after he was incarcerated, Epstein applied for the Palm Beach County Sheriff's work release program, and the Sheriff approved
pt 93I1 Power to Punish, and Proceedings Therefor 93k66 Appeal or Error 93k66O) k. Nature and Form of Remedy and Jurisdiction. Most Cited Cases Federal Courts 170B €556 170B Federal Courts 170BVIII Courts of Appeals 170BVIII(C) Decisions Reviewable 170BVIII(C)1 In General 170B1(554 Nature, Scope and E
ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO
Entities connected to both Federal Courts and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Salt Lake City
LOCATION
Alexander Acosta
PERSONScott Rothstein
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION