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l at some period of time." Id. citing Gregory I. Mitchell 634 F.2d 199, 203 (5th Cir. 1981). Further, "[w]h
D.E. 310- 1, 1 34. Exhibit 1 to her earlier statement of January 19, 2015 (D.E. 291-1), is the notification letter from the United States Attorney's Office, Southern District of Florida, signed by Assistant U.S. Attorney A. Marie Villafana, on behalf of United States Attorney R. Alexander Acosta. D.E. 291-1 at 17-20. Jane Doe No. 3
l at some period of time." Id. citing Gregory I. Mitchell, 634 F.2d 199, 203 (56 Cir. 1981). Further, "[w]h
D.E. 310- 1, ¶ 34. Exhibit 1 to her earlier statement of January 19, 2015 (D.E. 291-1), is the notification letter from the United States Attorney's Office, Southern District of Florida, signed by Assistant gEhEimesteposseillekete, on behalf of United States Attorney R. Alexander Acosta. D.E. 291-1 at 17-20. Jane Doe No. 3 even goe
that the "[m]ere passage of time need not result in a denial of leave to amend, but delay becomes fatal at some period of time." Id. ugt Gregory t Mitchell, 634 F.2d 199, 203 (5'h Cir. 1981). Further, "[w]hen there has been an apparent lack of diligence, the burden shifts to the movant to prove that the
D.E. 310-1, ¶ 34. Exhibit I to her earlier statement of January 19, 2015 (D.E. 291-I), is the notification letter from the United States Attorney's Office, Southern District of Florida, signed by Assistant U.S. Attorney A. Marie Villafana, on behalf of United States Attorney R. Alexander Acosta. D.E. 291-1 at 17.20. Jane Doe No. 3
Entities connected to both George Mitchell and Office, Southern District of Florida

Jeffrey Epstein
PERSONLeon Black
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Alfredo Rodriguez
PERSON
Eric Trump
PERSON
Joe Biden
PERSON
United States
LOCATION
Samantha Power
PERSON
Barack Obama
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Bradley Edwards
PERSONMaria Farmer
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Scarlett Johansson
PERSONthe Southern District
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Kentucky
LOCATIONJane Doe
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Alexander Acosta
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Paul Cassell
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Kenneth Marra
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Ken Starr
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Michael Reiter
PERSONCivil Division
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