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cations. Kenneth A. Marra From: Paul Cassell To: . (USAFLS Cc: (USAFLS)" , "Brad Edwards r < Date: 07/01/2013 02:21 PM Subject: RE:MTD in the Eleventh Circuit Hi Brad and I are preparing to file today in the Eleventh Circuit a motion to dismiss Epstein's frivolous interlocutory appeal, for reasons outlin
as you can. Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 S. 1400 E. , Room 101 Salt Lake Ci , UT 84112-0730 (phone) EFTA00209595 (fax You can access my publications on h
c. D.E. 310 at 15-16 citin International Broth. of Teamsters I. AFL-CIO, 32 F.R.D. 441, 442 (E.D.Mich. 1963). Since it is a precedential decision of the Eleventh Circuit, McLellan is binding authority. Accordingly, if the Federal Rules of Civil Procedure are applied to petitioners' motion to add Jane Doe No. 3 and J
rn District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, 4.74 Ninrih A tin* c AN / Paul G. Cassell Quinney College of Law at the Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black Jackie Perczek Black, Srebnick, Komspan & Stumpf, P.A. Imo Attorneys for Intervenor
tations to the victims — and having induced reliance by the victims—the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in
Submitted, s/ Bradley I. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro MX Vice Quinney College of Law at the University of Utah Attorneys for Jane Due 01 and Jane Doe 02 41 EFTA00229957 Case 9:08-cv-80736-KAM Document 48 Entered on FLSD Docket 0
Entities connected to both the Eleventh Circuit and Quinney College of Law

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Paul Cassell
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONJack Goldberger
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
the University of Utah
ORGANIZATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSONRoy Black
PERSON