Epstein Secrets

07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant Petitioner Jane Doe represented by Bradley James Edwards Fanner Jaffe Weissing Edwards Fistos & Lehrman PL I. Respondent United States of America Fax: 954-524-2822 Email: brad®pathtojustice.com LEAD

to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by Jane Doe. (Attachments: # 1 Exhibit October 9, 2008 letter from Brad Edwards, MIIRIPMEMIS Serterkeefi# 2 Exhibit October 15, 2008 Letter from Brad Edwards, Esquire to AUSA Dexter LeeXEdwards, Bradley) (Entered: 10/16/2008)

ocument. Signed by Judge Kenneth A. Marra on 2/12/2009. (ir) (Entered: 02/12/2009) 04/09/2009 37 NOTICE by Jane Doe of Change of Firm Affiliation (Edwards, Bradley) (Entered: 04/09/2009) 09/08/2010 la Administrative Order Closing Case. Signed by Judge Kenneth A. Marra on 9/8/2010. (tb) (Entered: 09/

2012 181 Notice of Supplemental Authority in support of Jane Doe #1 and Jan Doe #2's Response to Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction by Jane Doe (Edwards, Bradley) Modified on 12/11/2012 (Is). (Entered: 12/10/2012) 12 21/2012 M RESPONSE in Opposition re M Motion to Expedite Rul

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

Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction. The Court should deny the motion. Because the Government has filed a motion to dismiss alleging that the victims' pleadings are facially deficient

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

Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction. The Court should deny the motion. Because the Government has filed a motion to dismiss alleging that the victims' pleadings are facially deficient

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 Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney College of Law at the Universit

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

ing such information be filed under seal. EFTA00208791 WHEREFORE, the United States respectfully requests that the Motion to Dismiss for lack of Subject Matter Jurisdiction be sealed. DATED: November 7, 2011 Respectfully submitted, WIFREDO A. FERRER The undersigned hereby certifies and affirms that a copy of the fore

ATTORNEY SERVICE LIST Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [Service via CM/ECF] Paul G. Cassell S

rict Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrm

the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel

ATTORNEY SERVICE LIST Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [email protected] 954-524-2820 F

rict Court, Southern District of Florida Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrm

the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel