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lm Beach state court, the other in Miami federal court. Both cases purport to arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe No. 2. A federal statute directly on point provides that when an alleged sexual assault involving a child victim results in a "criminal proceeding,
18 U.S.C. § 3509(k) (emphasis added). When it comes to statutory construction, the mandatory nature of the word "shall" is well-settled. See, e.g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Mil
lm Beach state court, the other in Miami federal court. Both cases purport to arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe No. 2. A federal statute directly on point provides that when an alleged sexual assault involving a child victim results in a "criminal proceeding,
18 U.S.C. § 3509(k) (emphasis added). When it comes to statutory construction, the mandatory nature of the word "shall" is well-settled. See, e.g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' "use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Mi
tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
18 U.S.C. § 3509(k) (emphasis added). When it comes to statutory construction, the mandatory nature of the word "shall" is well-settled. See, e.g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Mil
ction. Introduction This lawsuit arises from a pending federal criminal action concerning, among other things, an alleged assault of the plaintiff Jane Doe, who, according to her complaint, on "numerous occasions" provided "massages" to Epstein with "no credentials to provide massage therapy" and was "
S.C. § 3509(k) (emphasis added). The word "shall" means that the statute's command is mandatory and not subject to a Court's discretion. See, e.g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' "use of a mandatory 'shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Mi
Entities connected to both Jane Doe and Lopez v. Davis

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSON
Adam D. Horowitz
PERSONLeon Black
PERSON
Alexander Acosta
PERSONStuart S. Mermelstein
PERSON
Sarah Kellen
PERSONFBI
ORGANIZATION
Jeffrey Marc Herman
PERSONthe Eleventh Circuit
ORGANIZATIONJANE DOE NO
PERSON
Julie K. Brown
PERSON
Southern District of New York
ORGANIZATION
Bill Richardson
PERSON
Michael Douglas
PERSON