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FLSD Docket 04/08/2011 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' RESPONSE TO JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF TH
t of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez v. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (5'h Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judicial admission is a formal
FLSD Docket 04:07)2011 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' RESPONSE TO JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF TH
t of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez v. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (5ih Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judicial admission is a formal
fforts to comply with the CVRA. (DE 6-8, 12-14.) On July 10, 2008, the Court set the matter for a hearing on July 11, 2008. (DE 5.) At the hearing, Jane Doe #2 was added as a Petitioner. (DE15 at 14.) The Court inquired of Petitioners what remedy they sought, and Petitioners made clear that they wanted t
nt of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez v. Bally's Louisiana, Inc. , 244 F.3d 474, 476-77 (5 di Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judicial admission is a form
KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 2 of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-Civ- JANE DOE #1 AND JANE DOE #2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. BRUCE E. REINHART, Intervenor INTERVENOR'S MOTION FOR SANCTIONS Comes
t of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez v. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judicial admission is a formal c
FLSD Docket 04/08/2011 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' RESPONSE TO JANE DOE NI AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF TH
t of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara'. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judicial admission is a formal co
AM Document 48 Entered on FLSD Docket 03/21/2011 Page 4 of 42 Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane Doe #2. Epstein performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) masturbation, touching of their sexual orga
nt of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (51° Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judicial admission is a formal
Entities connected to both Jane Doe and Louisiana, Inc.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSONLeon Black
PERSON
Salt Lake City
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSON
Sarah Kellen
PERSONFBI
ORGANIZATION
the University of Utah
ORGANIZATION
Dexter Lee
PERSON
S.J. Quinney College of Law
ORGANIZATION