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on, like the change of position by the Justice Department's local U.S. Attorney's Office, came only after Epstein's victims filed this lawsuit. See Mohasco Corp. v. Silver, 447 U.S. 807, 825, 100 S. Ct. 2486, 2497, 65 L.Ed.2d 532 (1980) (holding that an agency's "interpretation' of a statute cannot supersede
red the girls for Epstein's sexual gratification or participated in the sexual abuse themselves. The victims include the petitioners in this case, Jane Doe 1 and Jane Doe 2, who were 15 years old when first sexually abused by Epstein. B. Aug. 2006 Letter to Crime Victim about CVRA Rights Throughout the
her statutory rights under the CVRA. For example, in 2006 and before an indictment was drafted in 2007, the U.S. Attorney's Office told petitioner Jane Doe 2 in a letter that she had statutory rights "to confer with the attorney for the Government in the case," "to be treated with fairness," and to petit
eading Law: The Interpretation of Legal Texts 170 (2012) ("A word or phrase is presumed to bear the same meaning throughout a text ...."); cf. also Mohasco Corp. v. Silver. 447 U.S. 807, 826, 100 S.Ct. 2486.65 L.Ed.2d 532 (1980) (rejecting interpretation that would "giv[e] the word 'filed' two different mean
30 underage girls whom he sexually abused at his mansion in Palm Beach, Florida. The victims la ded one of the initial petitioners in this case, (Jane Doe I), who was 15 years old when Epstein first sexually abused her. Following the FBI's investigation, the U.S. Attorney's Office for the Southern Di
tered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Parti
Page: EFTA00010507 →. (DE 407 at ¶ 5.) The FBI ultimately determined that both Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI on August 7, 2007. (DE 407 at ¶ 6.) From January of 2007 through September
Page: EFTA00010508 →obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Next, the Court rejects the Government's contention that Jane Doe 2 is not protected by 31 EFTA00010537 ---
Page: EFTA00010538 →TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottinger LP 425 North Andrews Avenue, Suite
Page: EFTA00021442 →obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Given that the USAO-SDFL had told the victims that the CVRA applied, it was obligated to confer with them and
Page: EFTA00021459 →of all relevant circumstances, it is important to understand the very limited reference the victims made to Epstein's NPA in their civil lawsuits. Jane Doe I and 2 filed their civil lawsuits in about September 2008, only after their CVRA petition had been filed — and had succeeded in forcing the USAO- SDF
Page: EFTA00021493 →TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice T
Page: EFTA00022546 →obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Given that the USAO-SDFL had told the victims that the CVRA applied, it was obligated to confer with them and
Page: EFTA00022563 →also extends to "Other Potential Defendants," defined as any "other person or entity would could have been included as a potential defendant" in the Jane Does lawsuit alleging sex abuse. Obviously, the United States was a not sex abuser and could not have been included in the lawsuit against Epstein. 42
Page: EFTA00022591 →tered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE I AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Parti
Page: EFTA00027666 →. (DE 407 at ¶ 5.) The FBI ultimately determined that both Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI on August 7, 2007. (DE 407 at ¶ 6.) From January of 2007 through September
Page: EFTA00027667 →obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Next, the Court rejects the Government's contention that Jane Doe 2 is not protected by 31 EFTA00027696 ---
Page: EFTA00027697 →Entities connected to both Mohasco Corp. and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Salt Lake City
LOCATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Jay Lefkowitz
PERSONFBI
ORGANIZATION
the University of Utah
ORGANIZATION
Palm Beach
LOCATION
Jeffrey Sloman
PERSON
Jeffrey Marc Herman
PERSON