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dure do not allow them to intervene as parties to a prosecution." In re Amy Unknown, F.3d 2011 WL 988882 at *2 (5th Cir. Mar. 22, 2011). See also United Stases' Aguirre-Gonzalez, 597 F.3d 46, *Fed. R. Crim. P. 60 was adopted on April 23, 2008 and made effective on December 1, 2008. While this was after most
3/21/2011 Page 1 of 42 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 I. UNITED STATES I JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE REMEDI
he agreement secret. In particular, the agreement stated: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstei
d the government. Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States' BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district c
2008, with the filing of Petitioner's Emergency Petition for Enforcement of Crime Victim's Rights Act (DEI), and a Certificate of Emergency (DE2).' The Emergency Petition noted that Jeffrey Epstein had recently pled guilty to state court criminal charges (DEI at 1.) The Petition then alleged: 3. Upon information and
tes. Id. at *5. 32 EFTA00078866 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 33 of 54 The district court found that the United States' admission that Dr. Jackson was an employee was not a judicial admission, because "[w]hether Dr. Jackson was a federal employee under the FTCA appea
. 2005) (emphasis added). In W.R. me, petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the Rigas family. Two members of the Rigas family were convicted of securities fraud. A third was acquitted. Adelphia Communications
2008, with the filing of Petitioner's Emergency Petition for Enforcement of Crime Victim's Rights Act (DEl), and a Certificate of Emergency (DE2).' The Emergency Petition noted that Jeffrey Epstein had recently pled guilty to state court criminal charges (DE1 at 1.) The Petition then alleged: 3. Upon information and
IV-MARRAMOHNSON EFTA00208068 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 33 of 54 The district court found that the United States' admission that Dr. Jackson was an employee was not a judicial admission, because "[w]hether Dr. Jackson was a federal employee under the FTCA appea
. 2005) (emphasis added). In W.R. me, petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the Rigas family. Two members of the Rigas family were convicted of securities fraud. A third was acquitted. Adelphia Communications
2008, with the filing of Petitioner's Emergency Petition for Enforcement of Crime Victim's Rights Act (DE1), and a Certificate of Emergency (DE2).' The Emergency Petition noted that Jeffrey Epstein had recently pled guilty to state court criminal charges (DE1 at 1.) The Petition then alleged: 3. Upon information and
Entities connected to both United States and The Emergency Petition

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Southern District of New York
ORGANIZATION
Paul Cassell
PERSON
Michael Jackson
PERSON
Martha Stewart
PERSON
Eric Trump
PERSON
Supreme Court
ORGANIZATION
United States District Court
ORGANIZATION
Eric Holder
PERSON