Epstein Secrets

des strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States" Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens I. Hewitt Associates, 508 U.S. 24

r Lack of Subject Matter Jurisdiction was served via United States Mail this 24th day of January, 2012, upon Counsel for Petitioners Jane Doe #1 and Jane Doe #2, accompanied by a copy of the November 7, 2011 Sealed Order Granting Government's Motion for Limited Disclosure of Grand Jury Matter. Pursuant to

des strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States" Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens I. Hewitt Associates, 508 U.S. 24

rt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (

estion that Congress intended, but simply forgot, to provide additional remedies beyond those already specified. Courts agree. See United States v. Monzel, 641 F.3d 528, 542 (D.C. Cir. 2011) (holding that the CVRA's "carefully crafted and detailed enforcement scheme," provides "strong evidence that Co

-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JANE DOE 1 AND JANE DOE 2, Civil Action No. PETITIONERS, v. UNITED STATES OF AMERICA, RESPONDENT. 08-80736-CIV-MARRA • Government's Response to Petition

s strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States v. Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens v. Hewitt Associates, 508 U.S. 24

urt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (

s strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States v. Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens v. Hewitt Associates, 508 U.S. 24

urt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (

s strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly." United States States v. Monzel, 641 F.3d 528, 542 (D.C. Cir.), cert. denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens v. Hewitt Associates, 508 U.S. 24

rt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (

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

g enforcement of their rights in appellate courts had to shoulder the heavy burden traditionally associated with the "mandamus" relief. See U.S. v. Monzel, 641 F.3d 58, 532-33 (D.C. Cir. 2011) (discussing 18 U.S.C. § 3771(d)(3) and holding crime victims had to satisfy high mandamus standards); United S

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

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

g enforcement of their rights in appellate courts had to shoulder the heavy burden traditionally associated with the "mandamus" relief. See U.S. v. Monzel, 641 F.3d 58, 532-33 (D.C. Cir. 2011) (discussing 18 U.S.C. § 3771(d)(3) and holding crime victims had to satisfy high mandamus standards); United S

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

estion that Congress intended, but simply forgot, to provide additional remedies beyond those already specified. Courts agree. See United States v. Monzel, 641 F.3d 528, 542 (D.C. Cir. 2011) (holding that the CVRA's "carefully crafted and detailed enforcement scheme," provides "strong evidence that Co

U.S. Attorney's Office properly conferred in a timely fashion back in 2007"); id. at 24-25 ("If the Government had properly conferred with the two Jane Does ... [t]hese events would have provided Jane Doe 1 and 2 with much more information about Epstein's criminal conspiracy and its scope and operation,