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ng cases and concluding "the relevant case law unanimously agrees that the CVRA extends rights to crime victims before charges have been filed"). As the Eleventh Circuit has explained, "Congress is presumed to know the federal courts' interpretation of a statute that it intends to amend," and "[w]here there is no in
fense to the equitable claim of estoppel is the doctrine of 'unclean hands."' Bird v. Centennial Ins. Co‘, 11 F.3d 228, 234 (1st Cir. 1993) (citing Peabody Gas & Oil Co. v. Standard Oil Co., 284 Mass. 87, 187 N.E. 112, 113 (1933) ("[O]ne must come into a court of equity with clean hands in order to secure relief...."
. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that
Page: EFTA00021451 →defense to the equitable claim of estoppel is the doctrine of `unclean hands!" Bird v. Centennial Ins. Co., 11 F.3d 228, 234 (1st Cir. 1993) (citing Peabody Gas & Oil Co. v. Standard Oil Co., 284 Mass. 87, 187 N.E. 112, 113 (1933) ("[O]ne must come into a court of equity with clean hands in order to secure relief....
Page: EFTA00021492 →. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that
Page: EFTA00022555 →defense to the equitable claim of estoppel is the doctrine of `unclean hands!" Bird v. Centennial Ins. Co., 11 F.3d 228, 234 (1st Cir. 1993) (citing Peabody Gas & Oil Co. v. Standard Oil Co., 284 Mass. 87, 187 N.E. 112, 113 (1933) ("[O]ne must come into a court of equity with clean hands in order to secure relief....
Page: EFTA00022596 →Entities connected to both the Eleventh Circuit and Peabody Gas & Oil Co.

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Paul Cassell
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSON
Supreme Court
ORGANIZATION
the University of Utah
ORGANIZATION
Marc Rich
PERSON
Jeffrey Sloman
PERSONWalker
PERSONGarcia
PERSON
Madison
LOCATION
Michael Cohen
PERSONJacqueline Perczek
PERSON
Maine
LOCATIONU.S. Attorney's Office
ORGANIZATIONRoy Eric Black
PERSON