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Boulevard Miami, FL 33160 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Adler 18 401 East Las Ola
l state their appearances? 4 MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe
heir appearances? 4 MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE
oma Goan, Fiona 3)133 7 of 310 EFTA00180360 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 9 of 100 Oct. 15, 2007) (Moreno, J.) (citing Riley v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 292 F.3d 1334, 1337 (11th Cir. 2002)); accord, e.g., Tedder v. F.M.C. Corp., 590
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
d, "federal courts generally have the power to grant any appropriate relief in a cognizable cause of action brought pursuant to a federal statute." Moreno I Consolidated Rail Corp., 99 F.3d 782, 784 (6th Cir. 1996) (internal quotation omitted). Federal courts should "presume the availability of all ap
." ExecutiveGov <https://www.executivegov.cotn/2020/07/intelligence-community-unveils-ai-ethics-framework- principles-john-ratcliffe-quoted/> (7/24, Edwards) reported NDI Ratcliffe said in a statement, "The IC leads in developing and using technology crucial to our national security mission, and we canno
In Portland. The Hill <https://thehill.corn/homenews/administration/509029-fbi- says-its-investigating-specific-violations-of-federal-law-not> (7/25, Moreno, 2.98M) reports the "FBI defended its actions in ongoing confrontations between federal agents and demonstrators in Portland" in a Friday statement
idespread." Souleles said on a phone call with reporters on Thursday, "Every single algorithm, every signal datasat, has bias." ExecutiveGov (7/24, Edwards) reported NDI Ratcliffe said in a statement, "The IC leads in developing and using technology crucial to our national security mission, and we canno
ewsVi (7/25, story 14, 0:33, Perry, 3.83M) also reported on the "wall of veterans" briefly. FBI Defends Federal Action In Portland. The Hill (7/25, Moreno, 2.98M) reports the "FBI defended its actions in ongoing confrontations between federal agents and demonstrators in Portland" in a Friday statement
idespread." Souleles said on a phone call with reporters on Thursday, "Every single algorithm, every signal datasat, has bias." ExecutiveGov (7/24, Edwards) reported NDI Ratcliffe said in a statement, "The IC leads in developing and using technology crucial to our national security mission, and we canno
ewsVi (7/25, story 14, 0:33, Perry, 3.83M) also reported on the "wall of veterans" briefly. FBI Defends Federal Action In Portland. The Hill (7/25, Moreno, 2.98M) reports the "FBI defended its actions in ongoing confrontations between federal agents and demonstrators in Portland" in a Friday statement
odge workshop, 6 p.m. Wednes- day, town hall. 247 Edwards Lane. Palm Springs Leisure Services Board, 7 p.
ed her mother's Homewood Boulevard condo for about eight months. "She was a nice girl. . . . She had her problems, we'll just put it that way," Moreno said. Simmons previously lived in Nashua. N.H. Her landlord described her as a bright woman who had "is- sues" stemming from a ski- ing accident
Entities connected to both Bradley Edwards and Moreno

Jeffrey Epstein
PERSONJane Doe
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Kenneth Marra
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Alan Dershowitz
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George W. Bush
PERSONJack Scarola
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LOCATIONSouthern District
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LOCATIONMichael J. Pike
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