Epstein Secrets

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From: abaS) To: Cc: Subject RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SONY Case No. 1:20-cy-004844GIODCF Date: Monday, August 3, 2020 11:51:20 PM Attachments: 20320 Letter re Realest for Informagm

-80w4-KAM Document ≥ Entered L. .:LSD Docket 09/05/2L J Page 6 of 14 CASE NO.: 08-80804-CIV-MARRABOHNSON actionable underlying tort or wrong."' Posner'. Essex Ins. Co., 178 F.3d 1209, 1217-18 (11th Cir. 1999) (quoting Florida Fern Growers Assn'. Concerned Citizens, 616 So. 2d 562, 565 (Fla. 5th DC

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 (

on may be ordered detained.... 18 U.S.C. § 3148 (repealed). As the Sev- Ic th Circuit stated recently in United States Molt, 758 F.2d 1198 (1985) (Posner, J.): T]he change in the standard for bail pending appeal is not an ex post facto law. Even though it may work to the disadvant- age p f of a de

8's eighteenth birthday, and when Jane Doe #19 was seventeen years old. [NB: The police report describes a pattern of activity, including dates when Jane Doe #18 was seventeen years old.] Neither Jane Doe #18 nor #19 ever returned to Epstein's home. Although we have not yet obtained Jane Doe #18's teleph

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

ds, Inc., 387 F. Supp. 2d 794, 823 (N.D. Ill. 2005) ("ellipses are not a cure for misquotation and indeed are often the vehicle for misleading. See Posner, OVERCOMING LAW, 277 (1995) ("Beware a [lawyer] bearing ellipses.")). This CVRA rights enforcement action does not involve any claim for damages — m

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

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

ds, Inc., 387 F. Supp. 2d 794, 823 (N.D. Ill. 2005) ("ellipses are not a cure for misquotation and indeed are often the vehicle for misleading. See Posner, OVERCOMING LAW, 277 (1995) ("Beware a [lawyer] bearing ellipses.")). This CVRA rights enforcement action does not involve any claim for damages — m

also extends to "Other Potential Defendants," defined as any "other person or entity would could have been included as a potential defendant" in the Jane Does lawsuit alleging sex abuse. Obviously, the United States was a not sex abuser and could not have been included in the lawsuit against Epstein. 42