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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, Respondent. RESPONDENT'S REPLY TO PETITIONERS' OPPOSITION TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY
jurisdiction must properly be addressed and resolved before this Court takes any further action in the case. E.g. , University of South Alabama v. American Tobacco Co. , 168 F.3d 405, 411 (11th Cir. 1999) (holding that "the district court should have resolved the issue of subject matter jurisdiction before reaching
r Lack of Subject Matter Jurisdiction was served via United States Mail this 24th day of January, 2012, upon Counsel for Petitioners Jane Doe #1 and Jane Doe #2, accompanied by a copy of the November 7, 2011 Sealed Order Granting Government's Motion for Limited Disclosure of Grand Jury Matter. Pursuant to
solve the question of whether it has subject matter jurisdiction before proceeding any further with this matter. E.g., University of South Alabama American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (holding that "the district court should have resolved the issue of subject matter jurisdiction before reaching
rt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (
solve the question of whether it has subject matter jurisdiction before proceeding any further with this matter. E.g., University of South Alabama American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (holding that "the district court should have resolved the issue of subject matter jurisdiction before reaching
1 Entered on FLSD Docket 08)18:2008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a, JANE DOE NO. I, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. MOTION TO REMAND Plaintiff Jane Doe moves the Court to remand this act
removal statutes very strictly, and "all doubts about jurisdiction should be resolved in favor of remand to state court." Univ. of South Alabama I American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (citing Bums. Windsor Ins. Co., 31 F.3d 1092, 1095 (11th Cir. 1994), and Coker. Amoco Oil 3 EFTA00234426 Cas
led by Jeffrey Epstein. (Tein, Michael) (Entered: 09/05/2008) 09/15/2008 22 r 3" KB REPLY to Response to Motion re 11 MOTION to Remand filed by Jane Doe. (Kuvin, Spencer) (Entered: 09/15/2008) 09/16/2008 21 r 893 KB NOTICE of Substitution of Counsel by Theodore Jon Leopold on behalf ofJane Doe (
removal statutes very strictly, and "all doubts about jurisdiction should be resolved in favor of remand to state court." Univ. of South Alabama'. American Tobacco Co., 168 F.3d 405, 41I (11th Cir. 1999) (citing Burns'. Windsor Ins. Co., 31 F.3d 1092, 1095 (11th Cir. 1994), and Coker'. Amoco Oil 3 EFTA00175559
urt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (
lve the question of whether it has subject matter jurisdiction before proceeding any further with this matter. E.g., University of South Alabama v. American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (holding that "the district court should have resolved the issue of subject matter jurisdiction before reaching
urt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (
lve the question of whether it has subject matter jurisdiction before proceeding any further with this matter. E.g., University of South Alabama v. American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (holding that "the district court should have resolved the issue of subject matter jurisdiction before reaching
rt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (
lve the question of whether it has subject matter jurisdiction before proceeding any further with this matter. E.g., University of South Alabama v. American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (holding that "the district court should have resolved the issue of subject matter jurisdiction before reaching
rt support a finding of jurisdiction, are the following discovery requests: • An order from this Court that the Government provide Jane Doe #1 and Jane Doe #2 all information in its possession, including documents and correspondence, about why it decided not to prosecute Epstein's crimes against them (
lve the question of whether it has subject matter jurisdiction before proceeding any further with this matter. E.g., University of South Alabama v. American Tobacco Co., 168 F.3d 405, 411 (11th Cir. 1999) (holding that "the district court should have resolved the issue of subject matter jurisdiction before reaching
Entities connected to both Jane Doe and American Tobacco Co.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONSouthern District
LOCATION
Salt Lake City
LOCATION
A. Marie Villafana
PERSON
Sarah Kellen
PERSON
Donald Trump
PERSON
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATION