Epstein Secrets

ocument 57-1 Entered on FLSD Docket 04:07)2011 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' RESPONSE TO JANE DOE #1 AND JANE DOE #2'S MOTION FOR F

criminal prosecution" does not commence with the filing of a complaint and issuance of an arrest warrant, but only upon the return of an indictment. Kirby v. Illinois, 406 U.S. 682, 688-690 (1972). See also United States v. Pace, 833 F.2d 1307, 1312 (9th Cir. 1987) (filing of complaint and issuance of arrest warr

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' OPPOSITION TO JANE DOE #1 AND JANE DOE #2'S MOTION FOR

riminal prosecution" does not commence with the filing of a complaint and issuance of an arrest warrant, but only upon the return of an indictment. Kirby v. Illinois , 406 U.S. 682, 688-690 (1972). See also United States v. Pace , 833 F.2d 1307, 1312 (9th Cir. 1987) (filing of complaint and issuance of arrest war

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

tigation. The right to effective assistance of counsel does not attach until adversary judicial proceedings have been initiated against a defendant. Kirby v. Illinois , 406 U.S. 682 (1972). For this reason, the Sixth Amendment does not apply to a grand jury investigation, and a demand for information related to t

M Document 62 Entered on FLSD Docket 04/08/2011 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' RESPONSE TO JANE DOE #1 AND JANE DOE #2'S MOTION FOR F

criminal prosecution" does not commence with the filing of a complaint and issuance of an arrest warrant, but only upon the return of an indictment. Kirby v. Illinois, 406 U.S. 682, 688-690 (1972). See also United States v. Pace, 833 F.2d 1307, 1312 (9th Cir. 1987) (filing of complaint and issuance of arrest warr

the indispensable secrecy of the grand jury proceedings." United States v. R. Enterprises, Inc., 498 U.S. 292, 299 (1991) (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 EFTA00179094 importance." In

igation. The right to effective assistance of counsel does not attach until adversary judicial proceedings have been initiated against a defendant. Kirby v. Illinois, 406 U.S. 682 (1972). For this reason, the Sixth Amendment does not apply to a grand jury investigation, and a demand for information related to the