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

Yet Would Otherwise Evade Review. For all the reasons just explained, the Court clearly is in a position to address the CVRA violations alleged by the Jane Doe #1 and Jane Doe #2. Even assuming for sake of argument it was not, however, the Court would still clearly possess the ability to review the Governme

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

Yet Would Otherwise Evade Review. For all the reasons just explained, the Court clearly is in a position to address the CVRA violations alleged by the Jane Doe #1 and Jane Doe #2. Even assuming for sake of argument it was not, however, the Court would still clearly possess the ability to review the Governme

g agreement" of the judge presiding over the Matter. On July 24, 2017, and pursuant to the Court's admonition in the July 17 Order, we spoke with Brad Edwards, who is counsel for Jane Doe in both the Matter and the Jane Doe Matter. We informed Mr. Edwards that the defendants would like to make an applicat

monition in the July 17 Order, we spoke with Brad Edwards, who is counsel for Jane Doe in both the Matter and the Jane Doe Matter. We informed Mr. Edwards that the defendants would like to make an application to the judge presiding over the Matter for relief from the Protective Order as it applies to

f the,/ Letter, please confirm whether Jane Doe consents to the defendants' application in the Matter for relief from the Protective Order to use the Jane Doe Evidence in support of their motion to dismiss the Amended Complaint in the Jane Doe Matter. In addition to sending the July 7 Letter in the midst