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m taken by that party in a previous proceeding." Burnes v. Pemco Aeroplex, Inc., 291 F.3d 1282, 1285 (11th Cir. 2002), overruled in part, Slater v. United States Steel Corp., 871 F.3d 1174, 1176-77 (11th Cir. 2017). It is "an equitable concept intended to prevent the perversion of the judicial SO EFTA00299070 process
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 →ition under oath in a separate proceeding, and (2) these inconsistent positions were calculated to make a mockery of the judicial system." Slater v. United States Steel Corp. 871 F.3d 1174, 1181 (11th Cir. 2017) (internal quotation omitted). It should be remembered that Jane Doe 1 and 2 were confronting unprecedented sec
Page: EFTA00021496 →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 →ition under oath in a separate proceeding, and (2) these inconsistent positions were calculated to make a mockery of the judicial system." Slater v. United States Steel Corp. 871 F.3d 1174, 1181 (11th Cir. 2017) (internal quotation omitted). It should be remembered that Jane Doe 1 and 2 were confronting unprecedented sec
Page: EFTA00022600 →Entities connected to both United States Steel Corp. and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
United States
LOCATION
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
the University of Utah
ORGANIZATION
Jeffrey Sloman
PERSON
Marc Rich
PERSONthe Eleventh Circuit
ORGANIZATION
Supreme Court
ORGANIZATION
Harvey Weinstein
PERSON
Michael Cohen
PERSONGarcia
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONU.S. Attorney's Office
ORGANIZATIONWalker
PERSONSouthern District of Florida
LOCATION
Kenna
PERSON