Epstein Secrets

cument 36 Entered on FLSD Docket 06/12/2009 Page 1 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EP

IN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a di

FF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, thro

ISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469

ll inquiry, such as constitutional standing, that "serve to identify those disputes which are appropriately resolved through the judicial process." Whitmore, 495 U.S., at 155, 158, 110 S. Ct. 1717, 109 L. Ed. 2d 135. EFTA00222876 Case 9:09-cv-80469-KAM Document 36 Entered on FLSD Docket 06/12/2009

cument 20 Entered on FLSD Docket 05/22/2009 Page 1 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S M

REY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a di

PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, thro

ISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469

ll inquiry, such as constitutional standing, that "serve to identify those disputes which are appropriately resolved through the judicial process." Whitmore, 495 U.S., at 155, 158, 110 S. Ct. 1717, 109 L. Ed. 2d 135. (Emphasis added) Defendant's argument that the Court should abstain from deciding the

new court filing that the two had no contact for more than a decade before his death in August 2019." Her attorneys wrote, "Ghislaine Maxwell is not Jeffrey Epstein." On Thursday, they "asked a federal judge in Manhattan to release her from jail on $5 million bond, arguing that she did not pose a flight risk and

to wear to prevent any possibility of her harming herself." According to correspondent Eva Pilgrim, Maxwell "'vigorously denies' charges she helped Epstein recruit, groom, and abuse three teenage girls in the mid 90s, and will 'fight any allegations' against her. But some of Epstein's alleged victims w

US Attorney for the Eastern District of Missouri Jeffrey Jensen's review of the case." The Washington Tim

virus pandemic, as more employees switched to working from home, and medical facilities were cash-strapped and stretched thin because of COVID-19." Whitmore "said that, between March and April, IBM saw a 6,000% increase in spam attacks on information technology systems, leveraging COVID-19, EFTA00150713

case, the victims had (for example) no CVRA right to confer with prosecutors about a secret non-prosecution agreement barring federal prosecution of Epstein for crimes committed against the victims. This position contravenes the CVRA's plain language. The CVRA covers agencies involved in the "detection"

REC. S4260, 54269 (statement of Sen. Feinstein) (discussing § 377 l(d)(1) and explaining "[tjhis provision " The Government also attempts to raise Jeffrey Epstcin's "rights to Due Process." Gov't Resp. at 46. The victims are mystified as to why the Government would want to assert the rights of the criminal who

n- prosecution agreement (NPA) it negotiated with Jeffrey Epstein — an agreement that blocked federal pros

accessibility, mental incompetence, or other disability -- why the real party in interest cannot appear on his own behalf to prosecute the action." Whitmore v. Arkansas, 495 U.S. 149, 163 (1990) (citations omitted); see Lonchar v. Zant, 978 F.2d 637, 641 (11th Cir.I992) (applying Whitmore). Obviously th

matter, the defense attorneys would suffer no harm from release of the materials. Essentially what the defense attorneys are doing is appearing as Jeffrey Epstein's "next friend" to litigate issues on his behalf. But "a 'next friend' must provide an adequate explanation -- such as inaccessibility, mental incompe

hallenge to the legality of the non-prosecution agreement therefore cannot create a sufficient interest for the defense attorneys to intervene. Only Epstein has an interest in the validity of the non-prosecution agreement, and he has deliberately chosen not to intervene in this case.2 II. THE DEFENSE AT

erns only the crime victims, the Government, and Jeffrey Epstein. Simply put, Roy Black et al. have no rec

on FLSD Docket 05:02/2011 Page 6 of 8 other disability -- why the real party in interest cannot appear on his own behalf to prosecute the action." Whitmore I Arkansas, 495 U.S. 149, 163 (1990) (citations omitted) (addressing an individual's "next friend" status in the context of an appeal); see Loncharl

NT THIS PART OF THE VICTIMS' MOTION. In their motion (at pp. 4-6), the victims explained how the correspondence between government prosecutors and Jeffrey Epstein's counsel is highly relevant to their CVRA case. For example, they explained that significant parts of the correspondence specifically discuss the CV

A case. For example, they explained that significant parts of the correspondence specifically discuss the CVRA and the rights of the victims in the Epstein case. The victims have therefore asked this Court to make a finding of "admissibility" regarding the correspondence, consistent with an earlier ord

orrespondence between government prosecutors and Jeffrey Epstein's counsel is highly relevant to their CVR

accessibility, mental incompetence, or other disability -- why the real party in interest cannot appear on his own behalf to prosecute the action." Whitmore I Arkansas, 495 U.S. 149, 163 (1990) (citations omitted); see Lonchar • Zant, 978 F.2d 637, 641 (11th Cir.1992) (applying Whitmore). Obviously the