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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

y to suppress and eliminate competition by allocating packaged-ice customers in southeastern Michigan and the Detroit, Michigan, metropolitan area. McNulty had been an employee of Arctic Glacier, and was told of the conspiracy. Id. at 346-47. When he refused to participate in the conspiracy, he was fire

pellate court looked to the charging document, and the crime charged, to decide whether the individual had been directly and proximately harmed. In McNulty , the Sixth Circuit ultimately agreed with the district court's conclusion that McNulty was not a victim. 597 F.3d at 351-52. The appellate court fo

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

cy to suppress and eliminate competition by allocating packaged-ice customers in southeastern Michigan and the Detroit, Michigan, metropolitan area. McNulty had been an employee of Arctic Glacier, and was told of the conspiracy. Id. at 346-47. When he refused to participate in the conspiracy, he was fir

. 1993) 11 Williams v. Burns, 463 F.Supp. 1278, 1282 (D. Colo. 1979) 9 Yuan v. Rivera, 1998 WL 63404, at *5 (S.D.N.Y. Feb. 17, 1998) 12 Zerr v. Johnson, 894 F. Supp. 374, 376 (D. Colo. 1995) 16 EFTA00595587 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 6 of 29 INTRODUCTION The Plaintif

Frechtman v. Gutterman, 979 N.Y.S.2d 58 (1st Dep't 2014) 14 Front, Inc. v. Khalil, 24 N.Y.3d 713, 720 (2015) 13 Fuji Photo Film U.S.A., Inc. v. McNulty, 669 F.Supp.2d 405 (S.D.N.Y. 2009) 8 Gertz v. Robert Welch, Inc., 418 U.S. 323, 325 (1974) 17 Hawkins v. City of New York, No. 99 Civ. 11704 (RWS

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

cy to suppress and eliminate competition by allocating packaged-ice customers in southeastern Michigan and the Detroit, Michigan, metropolitan area. McNulty had been an employee of Arctic Glacier, and was told of the conspiracy. Id. at 346-47. When he refused to participate in the conspiracy, he was fir

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t Criminal Apprehension Program, who was working with state investigators, was then able to locate a 1993 rape case from Bloomington, Indiana, where McNulty was the named suspect. According to the article, McNulty was identified as the perpetrator after his DNA was matched to evidence from the crimes, a

, Politico (07/01, Gerstein, Cheney), BBC (07/01, Debusmann), USA Today (07/01, Groppe, Jansen), NewsNation Now (07/01, Whiteside), Deadline (07/01, Johnson), The Independent (07/01, O'Connell, Sommerlad), The Verge (07/01, Feiner, Valle), Voice of America (07/01, Bredemeier), Los Angeles Times (07/01,

saulting, resisting, or impeding certain officers during the Jan. 6 Insurrection. According to the article, the FBI played a key role in identifying McNulty by comparing images from the riot with other sources, ultimately charging him with multiple offenses, though some were later dropped. The FBI said a

ocument 311 Entered on FLSD Docket 02/06/2015 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 UNITED STATES JANE DOE NO. 1 AND JANE DOE NO. 2'S PROTECTIVE MOTION PURSUANT TO RULE 15 TO AMEND THEIR PETITION TO CO

ights that are related to the prosecution of the accused and sentencing of the guilty. These rights are not civil, but criminal in nature. See In re McNulty, 597 F.3d 344. 352 n.8 (6th Cir. 2010) ("The CVRA was not enacted to short circuit civil litigation to those with valid civil remedies available.")

Document 48 Entered on FLSD Docket 03/21/2011 Page 1 of 42 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 I. UNITED STATES I JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT A

cy to suppress and eliminate competition by allocating packaged-ice customers in southeastern Michigan and the Detroit, Michigan, metropolitan area. McNulty had been an employee of Arctic Glacier, and was told of the conspiracy. Id. at 346-47. When he refined to participate in the conspiracy, he was fir

AM Document 79 Entered on FLSD Docket 05/03/2011 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-Civ-Marra/Johnson JANE DOE #1 AND JANE DOE #2, Plaintiffs, I UNITED STATES OF AMERICA, Defendant. / MOTION TO INTERVENE OR IN THE ALTERNATIVE FOR A SUM SPONTE

cy to suppress and eliminate competition by allocating packaged-ice customers in southeastern Michigan and the Detroit, Michigan, metropolitan area. McNulty had been an employee of Arctic Glacier, and was told of the conspiracy. Id. at 346-47. When he refused to participate in the conspiracy, he was fir