Epstein Secrets

uld choose the more expansive interpretation. Not only is the CVRA "remedial legislation" that should be broadly construed to achieve its purposes, Edwards v. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be

an appropriate briefing schedule and hold a hearing on the appropriate remedy for those violations. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, 27 EFTA00178083 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

ledge or participation, a grave injustice has been committed by the authorities." Jon Kyl et al., On the Wings of Their Angels: The Scott Campbell, Stephanie Roper, Wendy Preston, Louarna Gillis, and Nita Lynn Crime Victims' Rights Act, 9 LEWIS & CLARK L. REV. 581, 602 (2005). Such a "grave injustice" is what

is raising, the Court must "take the factual allegations in the complaint as true and construe them in the light most favorable to the plaintiffs." Edwards v. Prime, Inc., 602 F.3d 1276, 1291 (11ih Cir. 2010). In the current posture of this case, the victims have pending a motion for "summary judgment"

ity to review this case. CONCLUSION The Court should deny the Government's motion to dismiss. DATED: December 5, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Te

ledge or participation, a grave injustice has been committed by the authorities." Jon Kyl et al., On the Wings of Their Angels: The Scott Campbell, Stephanie Roper, Wendy Preston, Louania Gillis, and Nila Lynn Crime Victims' Rights Act, 9 LEWIS & CLARK L. REV. 581, 602 (2005). That "grave injustice" is exactl

appropriate equitable remedy."). And the CVRA is obviously "remedial legislation" that should be broadly construed to achieve its remedial purposes. Edwards. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008). A good illustration of the broad power of district courts to remedy CVRA violation

ity to review this case. CONCLUSION The Court should deny the Government's motion to dismiss. DATED: December 5, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, UT \Ill A Tile UTOTAO 0. T M.TDIN A XT Tip T and Paul G. Cassell Pro Hac Vice Attorneys for Ja

ledge or participation, a grave injustice has been committed by the authorities." Jon Kyl et al., On the Wings of Their Angels: The Scott Campbell, Stephanie Roper, Wendy Preston, Louania Gillis, and Nila Lynn Crime Victims' Rights Act, 9 LEWIS & CLARK L. REV. 581, 602 (2005). That "grave injustice" is exactl

uld choose the more expansive interpretation. Not only is the CVRA "remedial legislation" that should be broadly construed to achieve its purposes, Edwards. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be ex

an appropriate briefing schedule and hold a hearing on the appropriate remedy for those violations. DATED: May 2, 2011 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER. JAFFE. WLETSSINrk 17 EFTA00208010 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 2

ledge or participation, a grave injustice has been committed by the authorities." Jon Kyl et al., On the Wings of Their Angels: The Scott Campbell, Stephanie Roper, Wendy Preston, Louania Gillis, and Nila Lynn Crime Victims' Rights Act, 9 LEWIS & CLARK L. REV. 581, 602 (2005). Such a "grave injustice" is what

RGES ARE FILED Winter, 2014 Reporter 104 J. Crim. L. & Criminology 59 * Length: 23898 words Author: PAUL G. CASSELL*, NATHANAEL J. MITCHELL** and BRADLEY J. EDWARDS*** * Ronald N. Boyce Presidential Professor of Criminal Law, S.J. Quinney College of Law at the University of Utah. ** Associate, Snow, Christensen &

CASSELL*, NATHANAEL J. MITCHELL** and BRADLEY J. EDWARDS*** * Ronald N. Boyce Presidential Professor of Cr

s have responded that because prosecutors never filed charges, government officials had no formal obligations to inform the girls. ' Scott Campbell, Stephanie Roper, Wendy Preston, Louarna Gillis, and Nila Lynn Crime Victims' Rights Act, Pub. L. No. 108-405, 178 Stat. 2260, 2261-65 (2004) (codified as amended at

l). 40 Does v. United States, 817 F. Supp. 2d 1337 (S.D. Fla. 2011). In the interest of full disclosure, two of the authors of this Article (Cassell and Edwards) are co-counsel for the victims in this case. The statement of the facts in this Article draws heavily on the victims' allegations as they have detai

tion Paul G. Cassell, Nathanael J. Mitchell, and Bradley J. Edwards, Crime Victims’ Rights During Criminal Investigati

lder strenuously objecting to the Department’s conclusions. Senator Kyl directly stated his view that “[w]hen Congress enacted the ' Scott Campbell, Stephanie Roper, Wendy Preston, Louarna Gillis, and Nila Lynn Crime Victims’ Rights Act, Pub. L. No. 108-405, 118 Stat. 2260, 2261-65 (2004) (codified as amended at