Epstein Secrets

S RESPONSE: (b) 2. (a) The government admits that, after Epstein's attorneys learned of the notification that the government planned to provide to Jane Doe #2, who claimed that she was not a victim, Epstein's attorneys contacted the USAO and objected to the procedures for notification and the legal bases

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). EFTA00208647 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 41 of 64 On September 26, 2011, the Court den

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Co

ESPONSE in Opposition re 280 Motion to Adopt/Join Jane Doe #3 and Jane Doe #4 filed by United States of Americ

pposition re 49 Plaintiff's MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Their Facts Accepted Becaus ernment's Failure to Contest Any of the Facts filed by United States of America. ( (Entered: 04/07/2011) 04/07/2011 59 RESPONSE in Opposition re 50 Plaintiff's MOTION Jane Doe #1 and Jane Do

49 Plaintiff's MOTION Jane Doe #1 and Jane Doe #2's Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts by Jane Doe. (Edwards, Bradley) (Entered: 03/21/2011) 03/21/2011 50 Plaintiff's MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing t

S RESPONSE: (b) 2. (a) The government admits that, after Epstein's attorneys learned of the notification that the government planned to provide to Jane Doe #2, who claimed that she was not a victim, Epstein's attorneys contacted the USAO and objected to the procedures for notification and the legal bases

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). EFTA00615908 Case 9:08-cv-80736-KAM Document 265-1 Entered on FLSD Docket 10/20/2014 Page 41 of 64 On September 26, 2011, the Court den

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Co

S RESPONSE: (b) 2. (a) The government admits that, after Epstein's attorneys learned of the notification that the government planned to provide to Jane Doe #2, who claimed that she was not a victim, Epstein's attorneys contacted the USAO and objected to the procedures for notification and the legal bases

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). EFTA00081155 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 41 of 64 On September 26, 2011, the Court den

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Co

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STATES RESPONSE: 2. (a) The government admits that, after Epstein's attorneys learned of the notification that the government planned to provide to Jane Doe #2, who claimed that she was not a victim, Epstein's attorneys contacted the USAO and objected to the procedures for notification and the legal bases

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). EFTA00179738 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 41 of 64 On September 26, 2011, the Court den

(the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Co

have a history of working diligently on behalf of victims of crime. While at the United States Attorney's Office for the Southern District of West Virginia, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. B

the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While there, he routinely conducted business, received medical atte

736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 10 of 29 attach after an indictment. The U.S. District Court for the Eastern District of Virginia has agreed with the Fifth Circuit's ruling in Dean: "Mite Fifth Circuit has noted that victims acquire rights under the CVRA even before prosecutio

o reply to the Government's Response (DE #58) to their Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE #49). The victims' proffered facts should all be accepted by the Court. The Government claims that it can prevail regardless of what the true f

filing and Behavioral Assessment Unit, Behavioral Analysis Units, and National Center for the Analysis of Violent Crime, F.B.I. Academy, Quantico, Virginia EDUCATION: 1970 A.B. Cornell University College of Arts and Sciences Honors Program in Psychology, 1969-1970 Alpha Epsilon Delta, 1969 (Vice Pre

estic Violence (e-learning course) THREAT ASSESSMENT GROUP@ WORKPLACE VIOLENCE PREVENTION COURSES TAUGHT BY DR. DIETZ:4 "Workplace Violence: Myths, Facts, and Corporate Prevention," Newport Beach, CA, December 16-18, 1993 Whirlpool, Nashville, TN, March 22, 1994 "Workplace Violence II: An Intensive