Epstein Secrets

ounsel for Petitioners Jane Doe #1 and Jane Doe #2. SE Jane Does 1 and 2 1 United States Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell EFTA00205480 Attorneys for Jane Doe # I and Jane

ion that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: Facial challenges to the legal sufficiency of

ASSISTANT U.S. ATTORNEY SERVICE LIST Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA EFTA00205491 United States District Court, Southern District of Florida Bradley Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Fort Lauderdale, FL 33301-3268 Paul G. Cassell S.J. Quinney Colle

ion that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: Facial challenges to the legal sufficiency of

ARIE VILLAFARA ASSISTANT U.S. ATTORNEY SERVICE LIST Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [Service via

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00601808 Case 9:08-cv-80736-KAM Documen

ing filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney U.S. Attorney's Office West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States EFTA0021

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

sistant U.S. Attorney Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Attorney for United States William L. Richey. Esq.

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

ing filed under seal. Assistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney Attorney for United States EFTA00223014 William L. Richey, Esq. Attorney for Subpoenaed Parties Riley Kiraly

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

n FLSD Docket 06/19/2009 Page 21 of 41 CASE NO: 08-CV-80119-MARRAJJOHNSON SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. k)Idberger aewpa.com Robert D. Critton, Esq. rcritton(&.bciclaw.com Isidro Manual Garcia isidrociarcia be

hoosing among incrimination, perjury, or contempt." United States ex rel. DRC, Inc. v. Custer Battles, LLC, 415 F.Supp.2d 628, 633 (E.D. Va. 2006). The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from silence. For example, in United States v. Two Parcels of Real Prop

IE VILLAFAIZIA ASSISTANT U.S. ATTORNEY SERVICE LIST Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 brad@pathto

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00660795 Case 9:08-cv-80736-KAM Documen

CM/ECF - Live natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Mag

he doctrine of fraudulent joinder to allow the removal of a case to federal court despite the presence of a non-diverse or forum-citizen defendant. The Eleventh Circuit has provided substantial guidance for the district courts in situations where a party removes a case from state court, alleging fraudulent joinder o