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e of Law at the University of Utah. Before coming to Utah. he was President of the Stanford Law Review, a law clerk for then-Judge Antonin Scalia on the D.C. Circuit and for Chief Justice Warren Burger of the Supreme Court. an Ass iate Deputy Attorney General with the . Justice Department (1986-88), and an Assi
hat appears to be personal numbers," the court papers say. Allegations in the documents say Epstein threatened victims — including Edwards' client Jane Doe — despite no-contact orders in effect. Epstein had Doe tailed by a private investigator as her trial date neared, the court filings say. One time,
the Southern District of Florida accepted Epstein's case for prosecution, and the FBI issued victim notification letters to my two clients. minors Jane Doc No. I and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the prosecutors and Epstein. On Sept. 24, 2007, the pr
formation by conceding that he in fact has the documents.” In re Grand Jury Subpoena, Dated April 18, 2003, 383 F.3d 905, 910 (9th Cir. 2004). The D.C. Circuit has recently refused to extend the act of production doctrine on facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Ci
notice that more than 90 days had elapsed since the filing of her motion (dkt. #453). On February 4, 2010, the magistrate judge granted in part Jane Doe’s motion to compel, specifically ruling that Epstein had to produce the discovery provided to him by state and federal prosecutors, his recent tax re
18, 2003, 383 F.3d 905, 910 (9th Cir. 2004). The D.C. Circuit has recently refused to extend the act of product
not require any mind to pick and choose. Indeed, Jane Doe’s request is significantly narrower that other req
ates v. Amodeois We have since clarified, however, that this sentence was based on a "quotation from a partial concurrence and partial dissent in the D.C. Circuit ... [and] is thus not the considered decision of either this court or the D.C. Circuit."17 In fact, we have expressly rejected the proposition tha
his victims. In return, prosecutors declined to bring federal charges. Shortly after Epstein entered his plea, two of his victims, proceeding as "Jane Doe 1" and "Jane Doe 2," filed suit against the Government in the Southern District of Florida under the Crime Victims' Rights Act ("CVRA"). The victim
lear and sensible boundary' that is marked by the formal initiation of criminal proceedings and that Chief Judge Srinivasan astutely recognized for the D.C. Circuit in Fokker Services. There is a world of difference between a court insinuating itself into a prosecutor's case before charges are filed and steppin
30 underage girls whom he sexually abused at his mansion in Palm Beach, Florida. The victims la ded one of the initial petitioners in this case, (Jane Doe I), who was 15 years old when Epstein first sexually abused her. Following the FBI's investigation, the U.S. Attorney's Office for the Southern Di
ity is "at its most limited when reviewing the Executive's exercise of discretion over charging determinations." Id. In Fokker, the question before the D.C. Circuit was whether the district court had the power to decline to enter a speedy trial waiver because it believed that the terms of the DPA were too lenie
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. I JEFFREY EPSTEIN, Intervenor. I INTERVENOR JEFFREY EPSTEIN'S BRIEF IN OPPOSITION TO
vice in the State of Florida. 3. Prior to assuming his teaching responsibilities, PAUL G. CASSELL clerked first for the U.S. Court of Appeals for the D.C. Circuit (1984-1985) and then from 1985 to 1986 clerked for the United States Supreme Court before serving as an Associate Deputy Attorney EFTA00188845 Ca
es by another underage victim. Epstein engaged in one or more of the following acts with each of the then-minor girls at his mansion: See Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane Doe I. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafte
, in which intervenors/appellants have no other appellate remedy, as they are not parties to the underlying action. See 2 As recently as May, 2013, the D.C. Circuit affirmed the continuing validity of the Perlman doctrine in In re Sealed Case, 716 F.3d 603 (D.C. Cir. 2013)(although finding a different standard
TATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT JANE DOE NO. 1 AND JANE DOES NO. 2, Plaintiffs-Appellees
Entities connected to both the D.C. Circuit 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
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Salt Lake City
LOCATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSON