Epstein Secrets

application of §2255 for appeal. See C.MA. v. Epstein, Case No. 08-CIV-80811 Marra/Johnson; and Jane Doe II v. Epstein, Case No. 09-CW-80489 Marra/Johnson. EFTA00207698 Case 9:08-cv-80893-KAM Document 128 Entered on FLSD Docket 03 05 2010 Page 23 of 36 Jane Doe v. Epstein Case No. 08-CV-80893-Marra

gainst reading a text in a way that makes part of it redundant," Nat'l Ass'n of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007) (citing TRW Inc. v. Andrews, 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in th

oena threatens to compromise `the indispensable secrecy of the grand jury proceedings.'" R. Enterprises , 498 U.S. at 299 (quoting United States v. Johnson , 319 U.S. 503, 513 (1943)). "The need to preserve the secrecy of an ongoing grand jury investigation is of paramount importance." In re Grand Jury

privilege applies, the burden is not met." United States v. Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission v. TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 122, 125 (2d Cir. 1980); United States v. Landof, , 591 F.2d 36, 38 (9th Cir. 1978); In

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

gainst reading a text in a way that makes part of it redundant," Nat'l Ass'n of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007) (citing TRW Inc. v. Andrews, 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in the

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

gainst reading a text in a way that makes part of it redundant," Nat'l Ass'n of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007) (citing TRW Inc. v. Andrews, 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in the

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

gainst reading a text in a way that makes part of it redundant," Nat'l Ass'n of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007) (citing TRW Inc. v. Andrews, 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in the

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

gainst reading a text in a way that makes part of it redundant," Nat'l Ass'n of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007) (citing TRW Inc. v. Andrews, 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in the

poena threatens to compromise `the indispensable secrecy of the grand jury proceedings.'" R. Enterprises , 498 U.S. at 299 (quoting United States I Johnson , 319 U.S. 503, 513 (1943)). "The need to preserve the secrecy of an ongoing grand July investigation is of paramount importance." In re Grand Jury

he privilege applies, the burden is not met." United States I Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission I TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 122, 125 (2d Cir. 1980); United States I Landof, , 591 F.2d 36, 38 (9th Cir. 1978); In

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

gainst reading a text in a way that makes part of it redundant," Nat'l Ass'n of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007) (citing TRW Inc. v. Andrews, 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in the

R THE SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Plaintiff, VS. JEFFREY EPSTEIN, 09 - 8059 1 Civil Action No. CIV-MARRP MAGISTRATE JUDGE JOHNSON Etrpy ,fir DC INTAKE APR 1 7 2009 STEVEN M. LARIMORE CLERK U.S. OIST. CT. S.O. OF FLA. MIAMI COMPLAINT AND Defendant. DEMAND FOR JURY TRIA

"against reading a text in a way that makes part of it redundant," Nat'l Ass'n of Home BuildersI, Defenders of Wildlife 551 U.S. 644 (2007) (citing TRW Inc. Andrews 534 U.S. 19, 31 (2001)), and the canon that "where words are employed in a statute which had at the time a well-known meaning ... in the la