Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENORS' REPLY TO JANE DOE #1 AND JANE DOES #2'S RESPONSE IN OPPOSITION TO INTERVENORS'

lack of awareness that Perlman had ever been applied outside the grand jury context, Opposition at 6, but a quick Westlaw search demonstrates that Penman has often been applied outside the grand jury context. See, e.g., Gotham Holdings, LP v. 7 EFTA00583460 D. The United States is a Disinterested

ar. Co., 244 F.2d 158, 162 & n.5 (11th Cir. 1955), a civil case. In just the few years since Mohawk, the Fourth Circuit found jurisdiction based on Penman in a civil case, Mezu v. Morgan State University, 495 Fed. Appx. 286, 289 (4th Cir. 2012); the Ninth Circuit has applied Perlman in a case arising u

treet. N.W. Adams. Geosgia 30303 Mee Ley Clerk of Court April 18, 2014 MEMORANDUM TO COUNSEL OR PARTIES Appeal Number: 13.12923-CC Case Style: Jane Doe'. Roy Black District Court Docket No: 9:08-cv-80736-KAM Far tales arid loans silt Raw ell I mamas say This Court requires all counsel to file docu

, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E

Street. N.W. Adams. Georgia 30303 John Ley Ckrtof Cost April 18, 2014 MEMORANDUM TO COUNSEL OR PARTIES Appeal Number: 13.12923-CC Case Style: Jane Doe'. Roy Black District Court Docket No: 9:08-cv-80736-KAM Far rules arid loans silt fern till uscourts.spy This Court requires all counsel to file d

, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E

0000 Importance: Normal You will have seen Epstein's latest (and belated) motion for limited prospective intervention. We are writing on behalf of Jane Doe #1 and Jane Doe #2 to invoke their right to confer on this motion with the Government. We would like to know your position on the motion. Please let

hat the Justice Department in other Courts of Appeals outside the Eleventh Circuit has argued that Mohawk implicitly narrows Perlman substantially. Penman is most commonly used by criminals who are targets of federal grand jury investigations, who seek to thwart and delay the Justice Department's inves

trict of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane Doe No. I and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the United States and Epstein. On September 24, 2007,

, but we decline to draw an arbitrary line. The victims' argument has an ipse dixit quality—that is, because our Court has never before applied the Penman doctrine outside of the grand jury context, we should not do so now. But we must ask instead whether applying the doctrine here makes sense. 11 E

United States (2014)*5 ri U Elt3CSC C?"' - cuv A." vs t. PIZCisalt‘if.-Lt,-ii Pr A December so, 2014, federal civil suit was filed in Florida by Jane Doe 1 and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the U.S. effort Department of„ Justices Nia with Rfla

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