Epstein Secrets

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

nment has committed. Settled law holds that "the nature of the remedy is to be determined by the nature and scope of the . . . violation." Nichols'. Hopper, 173 F.3d 820, 824 (11th Cir. 1999) (internal quotation omitted). And, "Nit the initial pleading stage, a plaintiff may establish standing based on

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

uld be a waste of time. Moreover, generally "the nature of the remedy is to be determined by the nature and scope of the . . . violation." Nichols'. Hopper, 173 F.3d 820, 824 (11th Cir. 1999) (internal quotation omitted). Until the Court identifies the scope of the Government's violations, it will be d

uit babes! Playboy vet Kendra Wilkinson shows off chest in one piace while celebrating 31st birthday with ‘number one ho’ in Arizona Sean Penn's son Hopper, 22, reveals his famous father wanted to name him ‘Steak’ due ta his love of red meat His mom Robin Wright wouldnt have gone for it New romance for

characterised as a ‘slap on the wrist’ for him, and ended up serving 13 months of his sentence, much of it in a liberal work-release programme Lawyer Brad Edwards, who represented several of Epstein’s victims, said: ‘Rather than punish him the way they would an average Joe, they sent a clear message that with e

Fort Lauderdale, FL 33301 wae SS Name and Title: Bradley J. Edwards, Director Name and Title: on Sulte2 Fort Lauderda