Epstein Secrets

of sovereign immunity bars an award of attorneys' fees against the United States unless there is express statutory authorization for such an award. Joel United States, 772 F.2d 1535, 1536 (11th Cir. 1985). Waivers of sovereign immunity are to be strictly construed in favor of the sovereign. Id. (citing United Sta

g & reh'g en banc denied, Case No. 09-15629, 435 F. App'x 914 (11th Cir. Jun. 29, 2011) (Table). Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

itution. See In re W.R. Huff 409 F.3d at 563. The statute pursuant to which Petitioners urge this Court to award restitution, however, does not make the United States liable for restitution for harms caused by others. Therefore, Petitioners are not entitled to restitution in this case. 5. Remaining Relief Request

, e.g., Friends of the Earth, Inc. I Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81, 185 (2000); Florida Wildlife Federation, Inc. I. South Florida Water Management Dist, 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. I. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2

Be Dismissed for Lack of Subject Matter Jurisdiction Because They Are Not Constitutionally Ripe. Conclusion For the reasons set forth above and in the United States' Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction, the United States respectfully requests that this Court enter an order dismissing

Agreement, Petitioners' reliance on In re Dean, 527 F.3d 391 (5th Cir. 2008), see DE 127 at 6, 7 This court may take judicial notice of its records. See United States I Rey, 811 F. 2d 1453, 1457 n.5 (11th Cir. 1987). 12 EFTA00205613 fails to support their efforts to seek rescission of the agreement. In In re

, e.g., Friends of the Earth, Inc. I Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81, 185 (2000); Florida Wildlife Federation, Inc. I. South Florida Water Management Dist, 647 F.3d 1296, 1302 (11th Cir. 2011); Phoenix of Broward, Inc. I. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2

: 1 of 25 No. 13-12923 IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT JANE DOE NO. 1 AND JANE DOES NO. 2, Plaintiffs-Appellees I. UNITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenor/Appellants INTERVENORS' RESPONSE TO MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Roy Black

to Mr. Epstein's attorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's counsel during the course of the negotiations. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100) at 2 ("To the knowledge of the government, the Jane Does have only r

hurch of Scientology'. United States, 506 U.S. 9 (1992) Cohenl. Beneficial Indus. Loan Corp., 337 U.S. 541 (1949) Florida Wildlife Federation, Inc. I. South Florida Water Management Dist., 647 F.3d 1296 (11th Cir. 2011) 14 6 18 Gill Gulfstream Park Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2

: 1 of 25 No. 13-12923 IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT JANE DOE NO. 1 AND JANE DOES NO. 2, Plaintiffs-Appellees I. UNITED STATES OF AMERICA, Defendant-Appellee ROY BLACK ET AL., Intervenor/Appellants INTERVENORS' RESPONSE TO MOTION TO DISMISS NON-PARTY INTERLOCUTORY APPEAL Roy Black

to Mr. Epstein's attorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's counsel during the course of the negotiations. See United States' Response to Supplemental Briefing in Support of Motion to Intervene (Doc. 100) at 2 ("To the knowledge of the government, the Jane Does have only r

hurch of Scientology'. United States, 506 U.S. 9 (1992) Cohenl. Beneficial Indus. Loan Corp., 337 U.S. 541 (1949) Florida Wildlife Federation, Inc. I. South Florida Water Management Dist., 647 F.3d 1296 (11th Cir. 2011) 14 6 18 Gill Gulfstream Park Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2