Epstein Secrets

ered on FLSD Docket 02/23/2015 Page 1 of 25 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 OF AMERICA, Respondent. RESPONDENT'S OPPOSITION TO JANE DOE NO. 1 AND JANE DOE NO. 2's PROTECTIVE MOTION PUR

Docket 02/23/2015 Page 23 of 25 government's waiver of sovereign immunity, and as such must be strictly construed. Center for Biological Diversity I. Hamilton, 453 F.3d 1331, 1334 (11th Cir. 2006), citing Spannaus I. Dept. of Justice 824 F.2d 52, 55 (D.C. Cir. 1987). "[A] waiver of the Government's soverei

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 OF AMERICA, Respondent. RESPONDENT'S OPPOSITION TO JANE DOE NO. 1 AND JANE DOE NO. 2's PROTECTIVE MOTION PUR

tional condition attached to the government's waiver of sovereign immunity, and as such must be strictly construed. Center for Biological Diversity I. Hamilton 453 F.3d 1331, 1334 (116 Cir. 2006), dtkgi Spannaus I. Dept. of Justice, 824 F.2d 52, 55 (D.C. Cir. 1987). "[A] waiver of the Government's sovereign

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 OF AMERICA, Respondent. RESPONDENT'S OPPOSITION TO JANE DOE NO. 1 AND JANE DOE NO. 2's PROTECTIVE MOTION PUR

tional condition attached to the government's waiver of sovereign immunity, and as such must be strictly construed. Center for Biological Diversity I. Hamilton, 453 F.3d 1331, 1334 (IP" Cir. 2006), citing Spannaus I. Dept. of Justice, 824 F.2d 52, 55 (D.C. Cir. 1987). "[A] waiver of the Government's soverei

s Jane Doe #1 and Jane Doe #2, then no additional investigation was required to determine if there was a good faith basis supporting the claim. Yet Jane Doe#4 waited over two years before asserting her claim. B. The CVRA Claims of Jane Doe #3 and Jane Doe #4 Are Barred by 28 U.S.C. § 2401(a) If petition

ional condition attached to the government's waiver of sovereign immunity, and as such must be strictly construed." Center for Biological Diversity I. Hamilton, 453 F.3d 1331, 1334 (11th Cir.2006), citing Spannaus, 824 F.2d at 55. Also, petitioners' contention that, because the CVRA contains no statute of