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Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S CONSOLIDATED STATEMENT OF UNDISPUTED MATERIAL FACTS AND MOTI
m letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA at the same time as the Office was not disclosing the NPA's existence to Jane Doe 5 and the other victiim."6 101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform her that he represented Jane Doe 1 a
he existence of the NPA.107 93. On January 10, 2008, Jane Doe I and Jane Doe 2 received victim notification letters from the FBI advising them that `Tiflis case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigati
ad been reached with Epstein. Mr. Edwards first learned of this fact on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's emergency petition. That pleading was the first public mention of the non-prosecution agreement and the first disclosure to Mr. Edwards and his cli
construction. After reciting the direct-and-proximate-harm language at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that Tiflis is an intentionally broad definition because all victims of crime deserve to have their rights protected ." 150 Cong. Rec. 510912 (Oct. 9, 2004) (e
eorgia before a Georgia notary), DE 4-2, Jane Doe No. I v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80
fantasies" and inflicting "untold damage," and opining that he should "be held accountable;" also quoting the plaintiff's attorney as opining that. Tiflis case is both about justice and making sure that a wealthy and powerful man knows that he is not above the law;" also quoting the plaintiff's attorn
Entities connected to both Jane Doe and Tiflis

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSONLeon Black
PERSON
Salt Lake City
LOCATION
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Jeffrey Sloman
PERSON
New York
LOCATION
Jeffrey Marc Herman
PERSON
Marc Rich
PERSON
the United States District Court
ORGANIZATION