Epstein Secrets

uld choose the more expansive interpretation. Not only is the CVRA "remedial legislation" that should be broadly construed to achieve its purposes, Edwards v. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be

an appropriate briefing schedule and hold a hearing on the appropriate remedy for those violations. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, 27 EFTA00178083 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

accessibility, mental incompetence, or other disability -- why the real party in interest cannot appear on his own behalf to prosecute the action." Whitmore v. Arkansas, 495 U.S. 149, 163 (1990) (citations omitted); see Lonchar v. Zant, 978 F.2d 637, 641 (11th Cir.I992) (applying Whitmore). Obviously th

urt should deny the defense attorneys' motion to intervene in this Crime Victims' Rights Act case.' DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. E-mail: [email protected] and Paul G. Cassell Pro Hac Vice A

s Crime Victims' Rights Act case.' DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. E-mail: [email protected] and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 4 The defense

on FLSD Docket 05:02/2011 Page 6 of 8 other disability -- why the real party in interest cannot appear on his own behalf to prosecute the action." Whitmore I Arkansas, 495 U.S. 149, 163 (1990) (citations omitted) (addressing an individual's "next friend" status in the context of an appeal); see Loncharl

ings in this matter, except for the portions that the victims have agreed should remain under seal. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 'ICAtT 1. A • ^I and Paul G. Cassell Pro Hac Vice ir% T el •

e agreed should remain under seal. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 'ICAtT 1. A • ^I and Paul G. Cassell Pro Hac Vice ir% T el • !I If Attorneys for Jane Doe #1 and Jane Doe #2 8

accessibility, mental incompetence, or other disability -- why the real party in interest cannot appear on his own behalf to prosecute the action." Whitmore I Arkansas, 495 U.S. 149, 163 (1990) (citations omitted); see Lonchar • Zant, 978 F.2d 637, 641 (11th Cir.1992) (applying Whitmore). Obviously the