Epstein Secrets

3/21/2011 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johason JANE DOE #1 and JANE DOE #2 I. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO HAVE THEIR FACTS ACCEPTED BECAUSE OF THE GOVERNMENT'S FAILURE TO CONTEST ANY OF THE FACTS COME NOW Jane Do

11 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 AND #2, Petitioners, I. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND TO HAV

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

at the party puts its muscles to work to perform with full energy and fairness the relevant express promises and reasonable implications therefrom." Stabile'. Stabile, 774 N.E.2d 673, 676 (Mass. App. Ct 2002). Here, far from putting its full energies towards protecting victims' their rights, the U.S. At

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

at the party puts its muscles to work to perform with full energy and fairness the relevant express promises and reasonable implications therefrom." Stabile'. Stabile, 774 N.E.2d 673, 676 (Mass. App. Ct. 2002). Here, far from putting its full energies towards protecting victims' their rights, the U.S. A

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

at the party puts its muscles to work to perform with full energy and fairness the relevant express promises and reasonable implications therefrom." Stabile'. Stabile, 774 N.E.2d 673, 676 (Mass. App. Ct. 2002). Here, far from putting its full energies towards protecting victims' their rights, the U.S. A