Epstein Secrets

/2011 Page 6 of 25 historically had broad authority to fashion equitable remedies . . . ." Hardison v. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004). The Eleventh Circuit has expressly required district courts to fashion appropriate equitable remedies when plaintiffs have proven a violation of statutory provisions. S

Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction. The Court should deny the motion. Because the Government has filed a motion to dismiss alleging that the victims' pleadings are facially deficient

05/2011 Page 6 of 25 historically had broad authority to fashion equitable remedies . . . ." Hardison. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004). The Eleventh Circuit has expressly required district courts to fashion appropriate equitable remedies when plaintiffs have proven a violation of statutory provisions. S

Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction. The Court should deny the motion. Because the Government has filed a motion to dismiss alleging that the victims' pleadings are facially deficient

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00601808 Case 9:08-cv-80736-KAM Documen

the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00660795 Case 9:08-cv-80736-KAM Documen

the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel