Epstein Secrets

t the United States, so the general six-year statute of limitations for suits against the United States applies." Id. hgt 28 U.S.C. § 2401(a), and Edwards Shalala, 64 F.3d 601, 605 (11'h Cir. 1995)(finding that section 2401(a) "sets an outside time limit on suits against the United States"). A "claim

lawsuits had to be based on the sexual abuse by Epstein. In a telephone interview conducted on April 7, 2011, by Jack Scarola, Esq., representing Brad Edwards, Esq. in Epstein'. Rothstein. Edwards. and L.M. Case No. 502009CA040800XXXXMBAG (Circuit Court, Palm Beach County, Fla.), Jane Doe #3 stated she wa

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

98 Case 9:08-cv-80736-KAM Document 290 Entered on FLSD Docket 01/20/2015 Page 6 of 14 limitations, no period of limitations applies, is refuted by Center for Biological Diversity.' That case dealt with the interpretation of the Endangered Species Act, and in particular, 16 U.S.C. § 1540(g)(1)(C). 453 F.3d at 1334. The Eleven

litigation involving two other victims (Dkt 290.1, Dkt 311 at 12), and she was making herself publicly available by giving interviews to the and to Edwards and Scarola in 2011. She was an adult in 2008 (25) and 2011 (28). She has a responsibility to join the lawsuit prior to the completion of JE sentenc

ane Doe No. 4 as petitioners. A proposed first amended petition is attached to this pleading. DATED: February 6. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE. WEISSING, P.L. DWARDS. FIST0S & LEHRMAN, and Paul G. Cassell Pro Hoc Vice S.J. Quinney College of Law at the

what I am saying. I hope that these people will come forward and tell the truth. I hope that they will call my attorney in Fort Lauderdale, Florida L Brad Edwards — so that all &the information can be presented to the court about what has happened to me and others. 9 EFTA00188671 Case 9:08-cv-80736-KAM Doc

tims' all agree. Given entirely reasonable. Indeed, any other course would have been foolhardy. 4 The Government's concession readily distinguishes Center for Biological Diversity v. Hamilton, 453 F.3d 1331 (11th Cir. 2006), which is clearly not an "ancillary criminal proceeding," but rather a civil enforcement action of the

Page 9 of 20 sexual offenses against children, and the Court should therefore look to the specific statute of limitations covering such crimes. See Edwards. Shalala, 64 F.3d 601, 605 (I I th Cir. 1995) ("[I]t appears contrary to the Supreme Court's directives . . . to apply a statute [of limitations] of

A00210686 Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 19 of 20 DATED: February 6.2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for the victims This d

tims' all agree. Given entirely reasonable. Indeed, any other course would have been foolhardy. 4 The Government's concession readily distinguishes Center for Biological Diversity. Hamilton, 453 F.3d 1331 (11th Cir. 2006), which is clearly not an "ancillary criminal proceeding," but rather a civil enforcement action of the En

the United States, so the general six-year statute of limitations for suits against the United States applies." Id. citing 28 U.S.C. § 2401(a), and Edwards v. Shalala, 64 F.3d 601, 605 (11th Cir. 1995)(finding that section 2401(a) "sets an outside time limit on suits against the United States"). A "cla

lawsuits had to be based on the sexual abuse by Epstein. In a telephone interview conducted on April 7, 2011, by Jack Scarola, Esq., representing Brad Edwards, Esq. in Epstein v. Rothstein. Edwards. and L.M., Jane Doe #3 stated she was first contacted by the FBI "in 2007 sometime." Exhibit C at 18. She was

F.2d at 55. Also, petitioners' contention that, because the CVRA contains no statute of limitations, no period of limitations applies, is refuted by Center for Biological Diversity. That case dealt with the interpretation of the Endangered Species Act, and in particular, 16 U.S.C. § 1540(g)(1)(C). 453 F.3d at 1334. The Elevent