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represented Jane Doe No. 1 and Jane Doe No. 2. (a) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. I. THE GOVERNMENT DID NOT VIOLATE PETITIONERS' § 3771(a)(2) RIGHT TO REASONABLE, ACCURATE, AND TIMELY NOTICE Supreme Court has repeatedly emphas
hat the Government is entitled to judgment as a matter of law, because it did not violate the CVRA rights of either petitioner. EFTA00211718 II. JANE DOE NO. 2 CANNOT INVOKE THE CVRA BECAUSE SHE OPENLY OPPOSED AND WAS HOSTILE TO THE PROSECUTION OF JEFFREY EPSTEIN Petitioners have not distinguished the
presented Jane Doe No. 1 and Jane Doe No. 2. (Id.) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. Petitioners' arguments and the record in this case simply do not establish that there was any violation of the petitioners' right to confer. See a
iolate the CVRA rights of either petitioner. EFTA00799825 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 2 of 32 II. JANE DOE NO. 2 CANNOT INVOKE THE CVRA BECAUSE SHE OPENLY OPPOSED AND WAS HOSTILE TO THE PROSECUTION OF JEFFREY EPSTEIN Petitioners have not distinguished the
ng criminal action derived from the same underlying allegations. See 18 U.S.C. § 3509(k). Discussion The parallel state criminal action pending in Palm Beach Circuit Court is still in the discovery phase. State of Florida v. Jeffi-ey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County).
12 Entered on FLSD Docket 06/20/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S MOTION FOR STAY Defendant Jeffrey Epstein respectfully moves for a mandatory stay of
ION Defendant Jeffrey Epstein's Motion to Stay this action is based on the incorrect premise that there are criminal actions pending against him in Palm Beach Circuit Court, State of Florida. Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County), and in the Southern District of F
t 25 Entered on FLSD Docket 0718/2008 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM OF LAW IN RESPONSE TO DEFENDANT'S MOTION FOR STAY Plaintiff, Jane Doe No
ng criminal action derived from the same underlying allegations. See 18 U.S.C. § 3509(k). Discussion The parallel state criminal action pending in Palm Beach Circuit Court is still in the discovery phase. State of Florida v. Jeffi-ey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County).
12 Entered on FLSD Docket 06/20/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S MOTION FOR STAY Defendant Jeffrey Epstein respectfully moves for a mandatory stay of
epresented Jane Doe No. 1 and Jane Doe No. 2. (ti) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. Petitioners' arguments and the record in this case simply do not establish that there was any violation of the petitioners' right to confer. See a
late the CVRA rights of either petitioner. EFTA00591462 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 3 of 33 II. JANE DOE NO. 2 CANNOT INVOKE THE CVRA BECAUSE SHE OPENLY OPPOSED AND WAS HOSTILE TO THE PROSECUTION OF JEFFREY EPSTEIN Petitioners have not distinguished the
Entities connected to both Palm Beach Circuit Court and JANE DOE NO

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Adam D. Horowitz
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSONStuart S. Mermelstein
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONChambers
PERSON
United States
LOCATIONMaria Farmer
PERSONLeon Black
PERSON
Jeffrey Marc Herman
PERSONFISTOS & LEHRMAN
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATION