Epstein Secrets

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

0 applies in federal proceedings to statements made in connection with prior state pleas"); see also United States v. Holmes, 794 F.2d 345, 349 (8th Cir.1986) (permitting the admission of a guilty plea from state court in a federal proceeding). 2 Because Epstein's lawyers are claiming that the correspond

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. [FNI] FNI. The background and focus of the federal grand Jury investigation is set forth in greater detail in an la camera submission of facts su

bears the burden of proving the applicability of the privilege," In re Bevil!, Bressler & Schubnan Asset Management Corp., 805 F.2d 120, 126 (3d Cir.1986), and privileges, "whatever their origins ... [should] not [be] lightly created or expansively construed." Nixon, 418 U.S. at 710, 94 5.O. at 3109

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. (FN1) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in cantera submission of facts s

ursuant to section 1292(6), we must of course dismiss the appeal if we are without jurisdiction. See Robinson v. Tanner, 798 F.2d 1378, 1379 (11th Cir.1986), cert. denied, 481 U.S. 1039, 107 S.Ct. 1979, 95 L.Ed.2d 819 (1987). Under section 1292(6), a district court may certify for appeal a non-final o

[3] [4] We review de novo the ultimate question of whether a warrantless search *960 was reasonable under the Fourth Amendment. United States v. Johnson, 256 F.3d 895, 905 (9th Cir.200 I ) (en banc). Our review necessarily encompasses a determination as to the applicable standard: no suspicion, rea

.3d 116. 120 n. 2 (3d Cit 1994); United States v. Santiago, 837 F.2d 1545. 1548 (11th Cir.1988); United States V. Gaviria, 805 F.2d 1108, 1112 (2d Cir.1986); United States v. Niver, 689 F.2d 520, 526 (5th Cir.1982); United States V. Mr, 592 F.2d 735, 739-40 (4th Cir.1979). [13] In his dissent, Judge

hat certain officers of the Buffalo Police Department violated federal criminal civil tights laws during and after the arrest of Mr. Aiken and Mr. Johnson. [FN I) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in COMM submission of facts sur

rsuant to section 1292(b), we must of course dismiss the appeal if we are without jurisdiction. See Robinson v, Tanner. 798 F.2d 1378, 1379 (11 th Cir.1986), cen. denied. 481 U.S. 1039, 107 S.Q. 1979, 95 L.Ed.2d 819 (1987). Under section 1292(b), a district court may certify for appeal a non-final ord

hort period in prison for punishment or other purposes but still needs supervision and trainin programs after release.")); see also United States Johnson. 529 U.S. 53. 59 (2000) ("The objectives of supervised release would be unfulfilled if excess prison time were to offset and reduce terms of super

ely on the defendant's status as a U.S. cit- izen is firmly estallished by our precedent. See, e.g.. United States Walczak, 783 F.2d 852, 854 (9th Cir.1986) (holding that jurisdiction over a U.S. citizen who violated a federal statute while in Canada los proper under the nationality principle); McKee!

JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 5, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOHNSON CASE NO.: 08-CV-80380-MARRALJOHNSON CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00182748 Case 9:08-cv-80119-KAM

allis, 28 F.3d 1399, 1409 (5th Cir.1994); United States v. Fitch, 964 F.2d 571, 574 (6th Cir.1992); United Stales v. Brown, 801 F.2d 352, 354 (8th Cir.1986). F1418. United States v. Tilley, 964 F.2d 66, 70 (Id Cir.1992) FN19. Dallis, 28 F.3d at 1409; Tilley, 964 F.2d at 70; United States v. Crawford,

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. (F141) FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in camera submission of facts s

ursuant CO section 1292(b), we must of course dismiss the appeal if we are without jurisdiction. See Robinson v. Tanner, 798 F.2d 1378, 1379 (11th Cir.1986), cert. denied, 481 U.S. 1039, 107 S.D. 1979, 95 L.Erl.2d 819 (1987). Under section 1292(b), a district court may certify for appeal a non-final o

hat certain officers of the Buffalo Police Department violated federal criminal civil rights laws during and after the arrest of Mr. Aiken and Mr. Johnson. IFNI] FNI. The background and focus of the federal grand jury investigation is set forth in greater detail in an in camera submission of facts su

bears the burden of proving the applicability of the privilege," In re Bevil!, Bressler if Schulman Asset Management Corp., 805 F.2d 120, 126 (3d Cir.1986), and privileges. "whatever their origins ... [should] not [be] lightly created or expansively construed." Nixon. 418 U.S. at 710, 94 S.Ct. at 310