Epstein Secrets

d these experiences deep in the past and I don't want to do anything at all to unearth all the hurt and pain it has taken me this long to process." Julie K. Brown, Prosecutors finally want to hear from Jeffrey Epstein's victims, MIAMI HERALD, 2019, https://www.miamiherald.com/news/state/florida/article2302754

.2d 1135, 1149 (11th Cir. 1986); see also Doll v. Brown, 75 F.3d 1200, 1205 (7th Cir. 1996) ("Of course

intentions, partial rescission would pose a significant risk of harm to certain victims, which must be considered in crafting an equitable remedy. The Eleventh Circuit has admonished courts considering equitable remedies to "bear in mind that a poorly crafted remedy may achieve justice for one by working a substan

pstein) 2 "Decisions by the former Fifth Circuit issued before October 1, 1981, are binding as precedent in the Eleventh Circuit." United States v. Brown, 342 F.3d 1245, 1246 n.1 (11th Cir. 2003). 12 EFTA00304753 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 13 of 25

/2011 Page 6 of 25 historically had broad authority to fashion equitable remedies . . . ." Hardison v. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004). The Eleventh Circuit has expressly required district courts to fashion appropriate equitable remedies when plaintiffs have proven a violation of statutory provisions. S

recedent in the Eleventh Circuit." United States' Brown, 342 F.3d 1245, 1246 n.1 (11th Cir. 2003). 12

05/2011 Page 6 of 25 historically had broad authority to fashion equitable remedies . . . ." Hardison. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004). The Eleventh Circuit has expressly required district courts to fashion appropriate equitable remedies when plaintiffs have proven a violation of statutory provisions. S

ity.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

lity.") (citation omitted); Liggett Group Inc., I Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

08-80804-CrV-MARRA/JOHNSON cite. See Mitchell'. Brown & Williamson Tobacco Corp., 294 F.3d 1309, 1314 (

he doctrine of fraudulent joinder to allow the removal of a case to federal court despite the presence of a non-diverse or forum-citizen defendant. The Eleventh Circuit has provided substantial guidance for the district courts in situations where a party removes a case from state court, alleging fraudulent joinder o