Epstein Secrets

www.hermanlaw.com - 4 - SERVICE LIST DOE vs. JEFFREY EPSTEIN CASE NO.: 08-CV-80119-MARRA/JOHNSON United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Michael R. Tein, Esq. [email protected] Robert D. Critton, Esq. [email protected]

Defendant has not to date filed a “responsive pleading” in this case within the meaning of Fed.R.Civ.P. 7(a). It is established in the courts of the Eleventh Circuit that a motion to dismiss is not a “responsive pleading” and does not affect a plaintiff’s right to amend the pleading once as a matter of course. W

us that you already have our May 19 and May 27 communications to the Deputy Attorney General, as well as our prior written submissions to CEOS and to the Southern District of Florida. In light of the significant volume of our prior submissions and to facilitate your review, we have drafted four supplemental submissions that will

s to engage in a criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these factors is present in this case. The Eleventh Circuit’s interpretation of the statute makes perfect sense: were § 1591 not limited in this fashion, it would threaten to criminalize a host of localized beha

uld handle victim impact statements in the context of a criminal sentencing. • All criminal prosecutors in the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) will undergo additional training on the CVRA, victim rights, and victim assistance issues to be completed no later than one year from t

intentions, partial rescission would pose a significant risk of harm to certain victims, which must be considered in crafting an equitable remedy. The Eleventh Circuit has admonished courts considering equitable remedies to "bear in mind that a poorly crafted remedy may achieve justice for one by working a substan

individual woman. As the statute makes clear, the essence of this crime is the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) `requires the specific intent to commit illegal

nsistent with each of the statutes prosecutors have identified. Accordingly, we respectfully request that you direct the U.S. Attorney's Office for the Southern District of Florida to discontinue its involvement in this matter, and return responsibility for this case to the State of Florida. 17 EFTA00013827

-9 ("a number of districts outside the Southern District of Florida (e.g., the Southern District of New York ...) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts committed by Epstein against [Jane Doe 1 and 2]. Epstein is thus subject t

. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that

till potentially be pursued in other districts, such as the Southern District of New York . . .."); DE 205-2 at 8-9 ("a number of districts outside the Southern District of Florida (e.g., the Southern District of New York ...) share jurisdiction and venue with the Southern District of Florida over potential federal criminal ch

. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that

ions. And not to be outdone, Epstein also intervened and succeeded in delaying the case for a year while he took a meritless interlocutory appeal to the Eleventh Circuit. See Jane Doe I and Jane Doe 2 v. U.S., 749 F.3d 999 (11th Cir. 2014). The upshot is that in this case involving federal sex offenses against two c

College of Law at the University of Utah 383 S. University St. Salt Lake Ci , UT 84112 March 4, 2019 Ms. Arian Fajardo Orshan U.S. Attorney for the Southern District of Florida 500 E. Broward Blvd. Ft. Lauderdale, FL 33394 Via email: [email protected] Re: Protecting the Rights of ieffrey Epstein's Victims Dear Ms.