Epstein Secrets

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

ument on this basis as well. Finally, a plea agreement is, in essence, a contract between a criminal defendant and the Government. United States v. Howie, 166 F.3d 1166, 1168 (11th Cir. 1999). Accordingly, plea agreements are governed by applicable principles of contract law. Allen v. Thompson, 161 F.

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

gument on this basis as well. Finally, a plea agreement is, in essence, a contract between a criminal defendant and the Government. United States'. Howie, 166 F.3d 1166, 1168 (11th Cir. 1999). Accordingly, plea agreements are governed by applicable principles of contract law. Allen. Thompson, 161 F.3d

FTA00361481 Tonja: cell, Fred: office, Jack: cell, 3:30pm Appt WED. MAY 15, 2013 PB-LSJ Reminder: Notice of Taking Video Tape Deposition of Brad Edwards on Wed, May jai Em ire Le al Support Inc, 401 East Las Olas Blvd, Suite 1400, Ft. Lauderdale, FL Reminder: Call. Reminder: to go to LSJ May 15-25i

r: Notice of Taking Video Tape Deposition of Brad Edwards on Wed, May jai Em ire Le al Support Inc, 401 Ea

lperin, Ada at 9 West 4762 Street, Rm# 4304 (Eileen: (Alan: 5:30pm Appt 6:00pm Appt w/Alan Dlugash ( 6:30pm Appt w/Steve Hanson d 7:00pm Appt w/Howie, the accountant Steve Hanson would like you to meet 7:30pm Haircut w/Patrick at the house! (Patrick: FRL MAY 24, 2013 NY-LSJ Reminder: Rich Kahn o