Epstein Secrets

ds—both of whom have repeatedly sued Mr. Epstein on behalf of others and who have, since this litigation commenced, brought yet another lawsuit, see Jane Doe 43 v. Epstein et aL, on behalf of Ms EM, who alleges commercial sexual activity while she was an adult—have interests beyond the plaintiff's case,

2 EFTA00589511 United States v. Bahadar, 954 F.2d 821, 827 (2d Cir. 1992), quoting Salerno, 937 F.2d 797, 805 (2d Cir. 1991). See, e.g., Davis v. Velez, 797 F.3d 192, 202-03 (2d Cir. 2015)(no abuse of discretion in finding witness unavailable where attorney had represented to court that client woul

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstein hereby mov

ry by coercive means is presumed to be `matters occurring before the grand jury' just as much as testimony before the grand jury"); United States v. Velez, 344 F.Supp.2d 329, 332 (D.P.R. 2004)(materials containing names of targets of grand jury investigation fell within Rule 6(e)); United States v. Di

") (collectively "Defendants") submit this memorandum in support of their motion to dismiss the First Amended Complaint ("FAC") filed by plaintiff Jane Doe ("Plaintiff') pursuant to Fed.R.Civ.P. 12(b)(2) and (6). The FAC represents the Plaintiff's second unsuccessful bite at the apple. On January 26,

A was enacted in December 2008, after the events alleged in the FAC had occurred and it has no application to the allegations set forth in the FAC. Velez v. Sanchez, 693 F.3d 308, 325 (2d Cir. 2012) ("there is a well-established presumption against the retroactive application of legislation, including