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ed. Thus, some of the proposed "undisputed material facts" are known to be false by counsel for petitioners. For example, during the investigation, Jane Doe #2 was not merely represented by counsel for Epstein, she was adverse to the investigation, and contacted other potential witnesses and advised them
ge and Justice Department official, of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar guidance. For example, there has been no civil or criminal finding by any judge or
empting to negotiate with the government for more than 30 months. As set forth in the Procedural History Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act("CVRA"), at the last hearing on the Petitioners' Emergency Peti
ge and Justice Department official, of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar guidance. For example, there has been no civil or criminal finding by any judge or
ng (but not limited to) . Because Epstein used a means of interstate commerce and knowingly traveled in interstate commerce to engage in abuse of Jane Doe #1 and Jane Doe #2 (and the other victims), he committed violations of federal law, including repeated violations of 18 U.S.C. § 2422. (DE48 at 3-4
ter, I included the following: We note the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar guidance. For example, there has been no civil or criminal finding by any judge or
ed. Thus, some of the proposed "undisputed material facts" are known to be false by counsel for petitioners. For example, during the investigation, Jane Doe #2 was not merely represented by counsel for Epstein, she was adverse to the investigation, and contacted other potential witnesses and advised them
ge and Justice Department official, of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar guidance. For example, there has been no civil or criminal finding by any judge or
empting to negotiate with the government for more than 30 months. As set forth in the Procedural History Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act("CVRA"), at the last hearing on the Petitioners' Emergency Peti
ge and Justice Department official, of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar guidance. For example, there has been no civil or criminal finding by any judge or
ding (but not limited to) . Because Epstein used a means of interstate commerce and knowingly traveled in interstate commerce to engage in abuse of Jane Doe #1 and Jane Doe #2 (and the other victims), he committed violations of federal law, including repeated violations of 18 U.S.C. § 2422. (DE48 at 3-4
to I included the following: We note the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar guidance. For example, there has been no civil or criminal finding by any judge or
Entities connected to both Jane Doe and Model Rules of Professional Conduct

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONthe Eleventh Circuit
ORGANIZATION
West Palm Beach
LOCATION
Southern District of New York
ORGANIZATION
Barry Diller
PERSONJames Eisenberg
PERSON
Anderson
PERSONRubin
PERSON
North
LOCATION
the Fifth Circuit
ORGANIZATIONthe Court of Appeals
ORGANIZATIONPalm Beach County Circuit Court
LOCATIONAguirre-Gonzalez
PERSON
Puerto Rico
LOCATIONDow Jones & Co.
ORGANIZATION