Epstein Secrets

A Case No. 08-80736-CIV-MARRA/JOHNSON EFTA00208063 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2n° Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c

08-80736-CIV-MARRA/JOHNSON EFTA00208087 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 52 of 54 cannot be granted. Continental Casualty Co. v. Fibreboard Corp., 4 F.3d 777, 778 (9ih Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas

ment that a victim be "directly and proximately harmed" encompassed the traditional "but for" and proximate cause analyses. Id. at 350, citing In Re Rendon Galvis , 564 F.3d 170, 175 (2 ' Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the

ve a remedy. However, this is not always the case. Indeed, courts have recognized that a controversy is moot if effective relief cannot be granted. Continental Casualty Co. v. Fibreboard Corp. , 4 F.3d 777, 778 (9 di Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas

mate cause analyses. Id. at 350, citing 27 EFTA00078861 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2nd Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c

s moot if effective relief 51 EFTA00078885 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 52 of 54 cannot be granted. Continental Casualty Co. v. Fibreboard Corp., 4 F.3d 777, 778 (9ih Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas