Epstein Secrets

Document 96 Entered on FLSD Docket 09:1672011 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION FOR "LIMITED" INTERVENTION OF JEFFREY EPSTEIN COM

... [and] 4. The existence of unusual circumstances militating either for or against a determination that the application is timely. Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). All four of the factors suggest that the Court should deny Epstein's motion as untimely. I. The length of t

Document 96 Entered on FLSD Docket 09/16/2011 Page 1 of 21 UNITED STATES 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 RESPONSE TO MOTION FOR "LIMITED" INTERVENTION OF JEFFREY EPSTEIN COM

... [and] 4. The existence of unusual circumstances militating either for or against a determination that the application is timely. Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). All four of the factors suggest that the Court should deny Epstein's motion as untimely. I. The length of t

Document 207 Entered on FLSD Docket 07/08/2013 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT

. 879, 882 (11th Cir. 2006), and is "not limited to chronological considerations but is to be determined from all the circumstances." Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Among the circumstances which must be considered is "the purpose for which intervention is sought." National

3); 15 US.C. §§ 78dd-2(a) (3), 78dd-3(a)(3). BI See, CL5 Complaint, SEC v. Johnson & Johnson, No. 11-cv-686 (D.D.C. Apr. 8, 2011) [hereinafter SEC v. Johnson & Johnson| (bribes paid through Greek and Romanian agents)), available at http: //wwwssec. gov/ litigation/ complaints/ 2011/comp21922. pdf; ; Criminal

ent to wrongfully influence the recipient. S.Rep. No. 95-114, at 10. % See 15 US.C. §§ 78dd-1(a), 78dd-2(a), 78dd-3(a). 7 See, C85 Complaint, SEC v. Monsanto Co., No. 05-cv-14 (D.D.C. Jan. 6, 2005) (among other things, the company paid a $50,000 bribe to influence an Indonesian official to repeal an unfavorabl

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT

. 879, 882 (11th Cir. 2006), and is "not limited to chronological considerations but is to be determined from all the circumstances." Stal(worth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Among the circumstances which must be considered is "the purpose for which intervention is sought." National

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstei

16 (11th Cir. 1983). "Timeliness" is "not limited to chronological considerations but is to be determined from all the circumstances." Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Among the circumstances which must be considered is "the purpose for which intervention is sought." National

M Document 93 Entered on FLSD Docket 09/02/2011 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, UNITED STATES OF AMERICA, Defendant. MOTION FOR LIMITED INTERVENTION OF JEFFREY EPSTEIN This is a motion

urable dimensions . . . [T]imeliness is not limited to chronological considerations but is to be determined from all the circumstances." Stallworth 'Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Those circumstances are considered in light of four factors: I. The length of time during which the would-be