Epstein Secrets

ourt, Southern District of Florida, pertaining to the sexual abuse of minors. fi The United States submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.

E "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. I Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may p

ourt, Southern District of Florida, pertaining to the sexual abuse of minors. fi The United States submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.

E "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. v. Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may

ourt, Southern District of Florida, pertaining to the sexual abuse of minors. fi The United States submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.

E "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. I Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may p

iscretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). In this case, that officer was the U.S. Attorney for the Southern District of Florida, and he exercised his discretion by deferring prosecution in favor of prosecution by authorities of the State of Florida. Thus, no feder

te "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. v. Metropolitan Dade County, 932 F.2d 1239, 1243 (11ih Cir. 1991)(citations omitted). 8 Respondent's Exhibit A Case No. 08-80736-CIV-MARRAM

orida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. The Government believes the absence of any charges in the Southern District of Florida can be judicially noticed pursuant to Fed.R.Evid. 201(b), because such information is either generally known within the territorial juri

diction of the trial court, or, is capable of accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned. Cash Inn of Dade, Inc. v. Metropolitan Dade County, 938 F.2d 1239, 1243 (11th Cir. 1991)("A district court may take judicial notice of public records within its files

ourt, Southern District of Florida, pertaining to the sexual abuse of minors. fi The United States submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.

2. "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. I Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may p

iscretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). In this case, that officer was the U.S. Attorney for the Southern District of Florida, and he exercised his discretion by deferring prosecution in favor of prosecution by authorities of the State of Florida. Thus, no feder

te "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. v. Metropolitan Dade County, 932 F.2d 1239, 1243 (11ih Cir. 1991)(citations omitted). 8 EFTA00078842 Case 9:08-cv-80736-KAM Document 62 En

G In accordance with Local Rules 4.6 of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission of Jay C. Howell for purposes of limited appearance as co-counsel on behalf of Jan

diction of the trial court, or, is capable of accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned. Cash Inn of Dade. Inc.'. Metropolitan Dade County, 938 F.2d 1239, 1243 (11th Cir. 1991)("A district court may take judicial notice of public records within its files