Epstein Secrets

tion of Epstein's federal case, on July 3, 2008, attorney Edwards sent a letter to the U.S. Attorney's Office comm

stitutional principle of separation of powers. Attorneys and Law Firms *1198 Paul Cassell, University of Utah College of Law, SALT LAKE CITY, UT, Bradley James Edwards, EdwardsPottinger, LLC, FORT LAUDERDALE, FL, for Petitioner. Richard Christian Komando, Bradley Garrison & Komando, ORANGE PARK, FL, for Amicus C

her. The U.S. Attorney's Office continued to conceal the existence of the NPA from all the victims for months to come. In mid- June *1233 of 2008, Bradley Edwards, the Fort Lauderdale, Florida attorney for several of Epstein's victims, contacted AUSA Villafana to inform her that he represented Jane Doe I and

for several of Epstein's victims, contacted AUSA Villafana to inform her that he represented Jane Doe I and, later, Jane Doe 2. AUSA Villafana and Edwards discussed the possibility of federal charges being filed against Epstein in the future. Edwards was led to believe that federal charges could stil

r, as the CVRA requires, she filed a petition for writ of mandamus. See 18 U.S.C. § 3771(d)(3): see also 16 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 3932 (3d ed. 2019) (explaining that a mandamus petition is "an original application to the court of appeals"). The question before

ing reasons, the Court should deny this Crime Victims' Rights Act case. DATED: May 17, 2011 7 motion to intervene in Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 EFTA00205017 Joseph L

ervene in Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, an

`satellite litigation"' that will frustrate the rule's goal of 'more effective operation of the pleading regimen.' Id. (citing 5A Wright & Miller, Federal Practice and Procedure § 1332, at 29 (1990)). motion is also untimely. On March 20, 2011, the victims filed their motion for summary judgment — the pleading

asons, the Court should deny Reinhart's motion to intervene in this Crime Victims' Rights Act case. DATED: May 16.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 6 EFTA00795279 Case 9:08-cv-80736-KAM Document 81 Entered on FLSD

is Crime Victims' Rights Act case. DATED: May 16.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 6 EFTA00795279 Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05)16.2011 Page 7 of 8 and Paul G. Cassell P

" `satellite litigation' that will frustrate the rule's goal of `more effective operation of the pleading regimen.' Id. (citing 5A Wright & Miller, Federal Practice and Procedure § 1332, at 29 (1990)). Reinhart's motion is also untimely. On March 20, 2011, the victims filed their motion for summary judgment — t

s R day of 2009: EFTA00234869 Case 9:08-cv-80893-KAM Document 87 Entered on FLSD Docket 06/12/2009 Page 26 of 26 Doe v. Epstein Page No. 26 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Counsel for Plaintiff Paul G. Cassell, Esq.

Page 26 of 26 Doe v. Epstein Page No. 26 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

as a factual allegation"). Factual allegations must be enough to raise a right to relief above the speculative level, see 5 C. Wright & A. Miller, Federal Practice and Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) ("Mlle pleading must contain something more ... than ... a statement o

ddress) LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Bradley James Edwards Rothstein Rosenfeldt Adler 401 East Las Olas Blvd Suite 1650 Ft. Lauderdale , FL 33301 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Paul

Entered: 06/08/2009) 06/08/2009 14k RESPONSE in Opposition re 144 Defendant's MOTION to Strike Cases from Current Trial Docket filed by Jane Doe. (Edwards, Bradley) (Entered: 06/08/2009) 06/08/2009 147 RESPONSE in Opposition re 104 Defendant's MOTION to Strike Cases from Current Trial Docket filed b

d as a factual allegation"). Factual allegations naist be enough to raise a right to relief above the speculative level, see 5 Wright & A. Miller, Federal Practice and EFTA00175635 Case 9:08-cv-i„ .19-KAM Docuri, 146 Enterer, ...i FLSD Docket 10i„,2008 Page 4 of 10 Case No. CV-80119-Marra-Johnson Page No

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

United States v. Treacv 19 603 F. Supp. 2d 670 (S.D.N.Y. 2009) STATUTES N.Y. Civil Rights Law § 79-h 3 OTHER 9 James Wm. Moore et al.. Moore's Federal Practice (3d ed. 2010) II EFTA00728013 Daily News, L.P. ("Daily News"), and Daily News journalist George Rush respectfully submit this reply memorandum o

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

United States v. Treacv 19 603 F. Supp. 2d 670 (S.D.N.Y. 2009) STATUTES N.Y. Civil Rights Law § 79-h 3 OTHER 9 James Wm. Moore et al.. Moore's Federal Practice (3d ed. 2010) II EFTA00207336 Daily News, L.P. ("Daily News"), and Daily News journalist George Rush respectfully submit this reply memorandum o