Epstein Secrets

overnment which may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United Stales, Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States' Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These

/21/2011 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANDE DOE #2 I. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHT ACT AND TO HAVE THEIR UNREDACTED PLEADI

ners argue that the Court should accept their Statement as true, despite its conclusory allegations and internal inconsistencies, solely because of the United States' failure to stipulate to the Statement. The Court should deny the motion because: (1) Petitioners have misstated that United States' efforts at reach

respond to the victims' motion for a finding of violation of the CVRA is untimely, as that is when the victims must begin drafting reply pleadings. See United States! Jefferson County, 720 F.2d 1511, 1516 (nth Cir. 1983) (listing factors to be considered in determining whether motion to intervene is timely). CERT

6) ("Nothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction"); Waytel United States, 470 U.S. 598, 607-08 (1985) (the decision whether to prosecute is "particularly ill-suited to judicial review," and "not readily susceptible to th

may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United Stales, Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States' Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin

to the government which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachm

t which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment inf

rts" language have routinely recognized that this language can create affirmative obligations to act. See, e.g., Hughes Communications Galaxy, Inc. United States, 26 Cl. Ct. 123, 135 (1992) ("A best efforts clause . . . can also affirmatively obligate."). Here, the action that is affirmatively required by the

may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United States. Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States, Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin

to the government which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachm

t which may be "favorable" to the victims, see Brady' Maryland, 373 U.S. 83 (1963) (discussing evidence "favorable" to defendants); United States'. Agurs, 427 U.S. 97 (1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment inf

rts" language have routinely recognized that this language can create affirmative obligations to act. See, e.g., Hughes Communications Galaxy, Inc. United States, 26 Cl. Ct. 123, 135 (1992) ("A best efforts clause . . . can also affirmatively obligate."). Here, the action that is affirmatively required by the

may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United States. Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States, Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These Standin