Epstein Secrets

SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney Co

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

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

basis, the Government claims to be free to raise extrinsic evidence outside the complaint, "such as testimony and affidavits." Id. at 1.n.1 (citing Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 1999)). To the extent the Government is attempting to raise a "factual" challenge to jurisdiction, the Go

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

basis, the Government claims to be free to raise extrinsic evidence outside the complaint, "such as testimony and affidavits." Id. at 1.n.1 (citing Makro Capital of America, Inc. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 1999)). To the extent the Government is attempting to raise a "factual" challenge to jurisdiction, the Govern

SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Ho11 wood Florida 33020 Fax: Paul G. Cassell S.J. Quin

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC Paul G. Cassell S.J. Quinney College of Law at the University of Utah 16 EFTA00795166

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations. Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (

SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-