Epstein Secrets

ters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, and Your Affiant's letter to was provided by the FBI. (Ex. I ). Your A Mantis letter to III was hand-delivered by myself to at t

ed to provide notification to victims in the short time that they had. jj Although all known victims were not notified, AUSA Ilindid call attorney Edwards to provide notice to his clients regarding the hearing. AUSA did this, even though she had no obligation to provide notice of a state court hearing

fense was confirmed when she was interviewed by 'Attorney Edwards filed his Motion on behalf of "Jane Doe," without

Cir. 2002) (relying on Black's Law Dictionary, in the context of a criminal case, for the definition of "pending" as "awaiting decision"); Swartz'. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending," expressly because "'pending' is not defined i

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

11 EFTA00304752 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 12 of 25 667, 671 (11th Cir. 1998); United States v. Meyers, 32 F.3d 411, 413 (9th Cir. 1994). One such fundamental principle of contract law is that contracts entered into in violation of law are void, and

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

1 1 EFTA00204902 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 12 of 25 667, 671 (11th Cir. 1998); United States'. Meyers, 32 F.3d 411, 413 (9th Cir. 1994). One such fundamental principle of contract law is that contracts entered into in violation of law are void, and