Epstein Secrets

Document 127 Entered on FLSD Docket 12/05/2011 Page 1 of 25 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 GOVERNMENT'S SEALED MOTION TO DISMISS FOR LACK OF SUBJECT

es not cite the applicable civil rule is that it has yet to state clearly whether it is willing to abide by the civil rules in this case. See, e.g., Gov't Resp. Mot. Order Not Withhold Evid., DE #59 at 6-7 (refusing to take a position on whether civil rules apply or not). Indeed, the Government has yet to

Document 127 Entered on FLSD Docket 12/05/2011 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO GOVERNMENT'S SEALED MOTION TO DISMISS FOR LACK OF SUBJECT

es not cite the applicable civil rule is that it has yet to state clearly whether it is willing to abide by the civil rules in this case. See, e.g., Gov't Resp. Mot. Order Not Withhold Evid., DE #59 at 6-7 (refusing to take a position on whether civil rules apply or not). Indeed, the Government has yet to

Document 106 Entered on FLSD Docket 10/10/2011 Page 1 of 27 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 SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE O

2). Epstein's lawyers, To be sure, as the Government points out, effective defense counsel should always explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130 S.C.t 1473, 1485 (2010)). But this is a far cry from proving there is a "right" to plea bargaining or that p

M Document 74 Entered on FLSD Docket 05/02/2011 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO THEIR MOTION TO USE CORRESPONDENCE

arding the correspondence, consistent with an earlier order of the magistrate judge. In response, the Government "takes no position" on the motion. Gov't Resp. at 1. Accordingly, this part of the victims' motion should be granted. II. NONE OF THE MATERIALS IN THE CORRESPONDENCE ARE BARRED FROM DISCLOSUR

Document 77 Entered on FLSD Docket 05;02.2011 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO THEIR MOTION FOR FINDING OF VIOLATI

gainst Jeffrey Epstein in the U.S. District Court, Southern District of Florida, . . . [the victims] cannot invoke any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply irreconcilable with § 3771(c)(1) of the CVRA. If an indictment is a prerequisite to CVRA rights, then depar

Document 76 Entered on FLSD Docket 05:02/2011 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 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO MOTION FOR ORDER DIRECTING THE U.S.

ernment also cites several cases in which district courts have declined to turn over to crime victims their own confidential pre-sentencing reports. Gov't Resp. at 3-4. These cases about judicial obligations say nothing about prosecutorial obligations under the CVRA "best efforts" provision. It is unsurpri

Document 75 Entered on FLSD Docket 05:02/2011 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO THEIR MOTION TO HAVE THEIR FACTS AC

ed by evidence in the record." The Government has briefly recounted a few facts in opposition to a small sliver of the victims' proposed facts. See Gov't Resp. to Victims' Motion to Have Facts Accepted at 11-13. But none of these facts are supported by any evidence at all. The Government should have at le

Document 344 Entered on FLSD Docket 12/17/2015 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08.80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 I UNITED STATES JANE DOE NO. 1 AND JANE DOE NO. 2'S MOTION FOR DEPOSITIONS OF GOVERNMENT WITNESSES COME NOW Jane Do

nt on this point, the Government has contested those requests — even arguing that its FBI agents properly and fully informed the victims. See, e.g., Gov't Resp. to 2d RFA 14(a) (The Government "denies that, during the period from September 24, 2007,through June 2008, the USAO-SDFL did not inform Jane Doe 1

he most recent court decision to carefully review the Justice Department's position is Jane Does #1 and #2 v. United States, No. 08-80736-CIV- MARRA/JOHNSON (S.D. Fla. Sept. 26, 2011). In that case, the court flatly rejected the Department's claim that rights attach only after charges are formally filed

rnment deny that it sent "victim" notification letters to Jane Doe 2, both before it negotiated the NPA and after. See, e.g., DE 407 at 12,11 93-95 (Gov't Resp. to Victims' Statement of Undisputed Facts) (conceding a victim notification letter was sent to Jane Doe 2 in Jan. 2008). As the Court is well awar

Document 77 Entered on FLSD Docket 05/02/2011 Page 1 of 29 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 REPLY TO GOVERNMENT'S RESPONSE TO THEIR MOTION FOR FINDING OF VIOLATI

against Jeffrey Epstein in the U.S. District Court, Southern District of Florida, . . [the victims] cannot invoke any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply irreconcilable with § 3771(c)(I) of the CVRA. If an indictment is a prerequisite to CVRA rights, then depar