Epstein Secrets

elated criminal prosecution when "special circumstances" so require in the "interests of justice." (Bold emphasis added). See also United States v. Kordel, 397 U.S. 1, 12 & n. 27, 90 S.Ct. 763, 769-70 & n.27 (1970). The Ventura Court went on to state that "situations where a defendant in both criminal

scayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300

659 F.2d 660, 668 (5th Cir. 1981) (add’l citations omitted). Examples of “special circumstances” provided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil action solely to obtain evidence for its criminal prosecution, (2) if the Government failed to advise t

______________________/ C.M.A., CASE NO.: 08-CV-80811-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, Defendants. ____________________________________/ Case 9:08-cv-80119-KAM

rovided by the Supreme Court in [United States v. Kordel] are: (1) if the Government brought the civil act

Defendant. ____________________________________/ JANE DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff,

her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Comm' n I Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstanc

/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. C.M.A., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80811-MARRA/JOHNSON JANE DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, Defendants. -2- EFTA00222206 Case 9:08-cv-80119-KAM Document 121

her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Con:nen, Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstances'

/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. C.M.A., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80811-MARRA/JOHNSON JANE DOE, CASE NO.: 08-CV-80893-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, Defendants. -2- EFTA00222762 DOE II, Plaintiff, vs. JEFFREY EPS

evidence for its criminal prosecution," or (2) "fail to advise the defendant in its civil proceeding that it contemplates his criminal prosecution." Kordel, 397 U.S. at 11-12 (emphasis added). In Kordel, a corporate executive was convicted of violating the Food, Drug, and Cosmetic Act partly on the basi

.' Questions about Epstein's deal started to surface after a series of lawsuits were filed by two of his alleged victims. The women, identified as Jane Doe 1 and Jane Doe 2, claim in court papers that they were unaware of the secret deal being made between the defense team and prosecutors back in 2007 tha

evidence for its criminal prosecution," or (2) "fail to advise the defendant in its civil proceeding that it contemplates his criminal prosecution." Kordel, 397 U.S. at 11-12 (emphasis added). In Kordel, a corporate executive was convicted of violating the Food, Drug, and Cosmetic Act partly on the ba

.' Questions about Epstein's deal started to surface after a series of lawsuits were filed by two of his alleged victims. The women, identified as Jane Doe 1 and Jane Doe 2, claim in court papers that they were unaware of the secret deal being made between the defense team and prosecutors back in 2007 tha

her unfair injury; or (4) any other special circumstances indicating unconstitutionality or even impropriety. Incendy at 956 (citing United States' Kordel, 397 U.S. I, 11 (1970)). See also Securities and Exchange Comm'nl. Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o 'special circumstances'

ROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. : Good morning, Your Honor. Sid for Jane Doe II. THE COURT: Good morning. MR. WILLITS: Good morning, Your Honor