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F.2d 1324, 20 EFTA00299040 1325 (9th Cir. 1975). As this Court has recognized, "a contracting party is the paradigm of an indispensable party." HDR Engineering, Inc. v. R.C.T. Engineering, Inc., No. 08- 81040-CIV-ICAM, 2010 WL 2402908, *2 (S.D.Fla. June 15, 2010) (citation omitted). "Parties to a contract are ind
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 OF AMERICA, Respondent. I JEFFREY EPSTEIN, Intervenor. I INTERVENOR JEFFREY EPSTEIN'S BRIEF IN OPPOSITION TO
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 →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 →al acceptance of the inconsistent later position would create the perception that either the earlier or later court was misled." Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the filing of a civil court complaint as an earlier "proceeding," Epstein does n
Page: EFTA00021495 →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 →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 →al acceptance of the inconsistent later position would create the perception that either the earlier or later court was misled." Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171, 1182 (11th Cir. 2013)). In this case, even treating the filing of a civil court complaint as an earlier "proceeding," Epstein does n
Page: EFTA00022599 →Entities connected to both HDR Engineering, Inc. and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
United States
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSONLeon Black
PERSON
Salt Lake City
LOCATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
the University of Utah
ORGANIZATION
Dexter Lee
PERSON
S.J. Quinney College of Law
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION
Jeffrey Sloman
PERSON
Marc Rich
PERSONthe Eleventh Circuit
ORGANIZATION
Supreme Court
ORGANIZATION