Epstein Secrets

Bradley J. Edwards FARMER, JAFFEE, WEISSING EDWARDS, FISTOS & LEHRMAN, P.L. Paul G. Cassell Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209494 TABLE OF CONTENTS INTRODUCTION 1 I. THIS COURT SHOULD IMMEDIATELY DISMISS EPSTEIN'S APPEAL IN LIGHT OF HIS CONCESSION THAT

ments for dismissal: first, that this Court lacks jurisdiction over such an interlocutory appeal in light of the Supreme Court's recent decision in Mohawk Industries, Inc.'. Carpenter, 130 S. Ct. 599 (2009) (attorney-client privilege ruling not immediately appealable; any injury can be addressed at conclusion of case)

cable statute of limitations for prosecuting him for his federal sex abuse crimes appears to be ten years. 18 U.S.C. § 3283. Epstein sexually abused Jane Doe #1 and Jane Doe #2 (and dozens of other similarly situated young girls) from 2002 to 2005. As a result, if Epstein can succeed in stalling this case

sponsibility [to police prejudgment tactics of litigants] if the appellate courts do not repeatedly intervene to second-guess prejudgment rulings." Mohawk Industries, Inc.' Carpenter, 558 U.S. 100, 106 (2009) (internal citations omitted). This Court has repeatedly explained its reluctant to grant a stay pending appeal

ISTOS & LEHRMAN, P.L. Paul G. Cassell S. J. Quinney College of Law at the University of Utah Attorneys for Plaintiffs-Appellees Jane Doe No.1 and Jane Doe No. 2 EFTA00209567 CERTIFICATE OF INTERESTED PERSONS Pursuant to 11th Cir. R. 26.1, Jane Doe No. 1 and Jane Doe No. 2, through undersigned couns

pstein's claim below that a denial of an assertion of privilege can be immediately appealed, the Supreme Court has recently concluded otherwise. In Mohawk Industries, Inc.' Carpenter, 130 S. Ct. 599 (2009), the Supreme Court affirmed this Circuit and rejected an effort by a defendant to take an interlocutory appeal of