Epstein Secrets

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

proceedings and the Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (DE I, the "Petition"), through which Petitioners Jane Doe #1 and Jane Doe #2 have advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject matter jurisdiction.1 This Court l

basis, the Government claims to be free to raise extrinsic evidence outside the complaint, "such as testimony and affidavits." Id. at 1.n.1 (citing Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 1999)). To the extent the Government is attempting to raise a "factual" challenge to jurisdiction, the Go

orney's Office for violating Jane Doe #1 and Jane Doe #2's rights; • A monetary sanction imposed against the U.S. Attorney's Office, to be paid to Jane Doe #1 and Jane Doe #2 directly or to any other appropriate person or entity;; • An order establishing the precise rule regarding the timing of the obli

basis, the Government claims to be free to raise extrinsic evidence outside the complaint, "such as testimony and affidavits." Id. at 1.n.1 (citing Makro Capital of America, Inc. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 1999)). To the extent the Government is attempting to raise a "factual" challenge to jurisdiction, the Govern

orney's Office for violating Jane Doe #1 and Jane Doe #2's rights; • A monetary sanction imposed against the U.S. Attorney's Office, to be paid to Jane Doe #1 and Jane Doe #2 directly or to any other appropriate person or entity;; • An order establishing the precise rule regarding the timing of the obli

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

proceedings and the Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (DE I, the "Petition"), through which Petitioners Jane Doe #1 and Jane Doe #2 have advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject matter jurisdiction.' This Court la

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

proceedings and the Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (DE I, the "Petition"), through which Petitioners Jane Doe #1 and Jane Doe #2 have advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject matter jurisdiction.' This Court la

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

proceedings and the Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (DE I, the "Petition"), through which Petitioners Jane Doe #1 and Jane Doe #2 have advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject matter jurisdiction.' This Court la

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

FLSD Docket 07/05/2013 Page 2 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United Sta

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (