Epstein Secrets

• Government's Response to Petitioners' Submission on Proposed Remedies The United States of America, by Byung J. Pak, United States Attorney for the Northern District of Georgia, and Jill E. Steinberg and Nathan P. Kitchens, Special Attorneys for the Southern District of Florida, files this response to Petitioners' proposed

other remedies that it simply forgot to incorporate expressly") (quoting Mertens v. Hewitt Associates, 508 U.S. 248, 254 (1993)); United States v. Hunter, 548 F.3d 1308, 1315 (10th Cir. 2008) 10 EFTA00010551 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 P

the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00021446 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 6 of 70 THIS CASE MUST BE DECIDED

d 58, 532-33 (D.C. Cir. 2011) (discussing 18 U.S.C. § 3771(d)(3) and holding crime victims had to satisfy high mandamus standards); United States v. Hunter, 548 F.3d 1308, 1315 (10th Cir. 2008) (same). Interestingly, Congress has since essentially overruled both of those decisions. See 18 U.S.C. § 3771

the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00022550 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 6 of 70 THIS CASE MUST BE DECIDED

d 58, 532-33 (D.C. Cir. 2011) (discussing 18 U.S.C. § 3771(d)(3) and holding crime victims had to satisfy high mandamus standards); United States v. Hunter, 548 F.3d 1308, 1315 (10th Cir. 2008) (same). Interestingly, Congress has since essentially overruled both of those decisions. See 18 U.S.C. § 3771