Epstein Secrets

employee as the source of the information. (2) Appearance. A former employee makes an appearance when he is physically present before an employee of the United Slates, in either a formal or informal setting. Although an appearance also may be accompanied by certain communications, an appearance need not involve an

ecified in paragraphs (fXI) (i) through (f)(l)(iv) of this section, e.g., as when a former employee directs remarks to an employee representing the United Slates as a party or intervenor in a Federal or non-Federal judicial proceeding. A Conner employee does not direct his communication or appearance to a bys

id not participate as a Government employee. Example 7 to paragraph (hX2): An employee of the Department of State participated in the development of the United States' position with respect to a proposed treaty with a foreign government concerning transfer of ownership with respect to a parcel of real property and

esolving prisoner disputes. Construing the CVRA in the way that "See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States v. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United St

ove and beyond on behalf of these victims. A request was made to the Palm Beach County Sheriff's Office ('PBSO") that it notify the U.S. Attorney's Office of Epstein's release so that further release notification could be made, but PBSO did not honor that request. 3. The right not to be excluded from public court

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

ove and beyond on behalf of these victims. A request was made to the Palm Beach County Sheriff's Office ("PBSO") that it notify the U.S. Attorney's Office of Epstein's release so that further release notification could be made, but PBSO did not honor that request. 3. The right not to be excluded from public court

employee as the source of the information. (2) Appearance. A former employee makes an appearance when he is physically present before an employee of the United Slates, in either a formal or informal setting. Although an appearance also may be accompanied by certain communications, an appearance need not involve an

id not participate as a Government employee. Example 7 to paragraph (hX2): An employee of the Department of State participated in the development of the United States' position with respect to a proposed treaty with a foreign government concerning transfer of ownership with respect to a parcel of real property and

esolving prisoner disputes. Construing the CVRA in the way that "See 18 U.S.C. § 113 (assault within territorial jurisdiction of the United States); United States. Anderson, 528 F.2d 590, 591 (5th Cir. 1976) (in prosecution for assault with intent to commit murder within territorial jurisdiction of United Stat

ove and beyond on behalf of these victims. A request was made to the Palm Beach County Sheriff's Office ('PBSO") that it notify the U.S. Attorney's Office of Epstein's release so that further release notification could be made, but PBSO did not honor that request. 3. The right not to be excluded from public court

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

ove and beyond on behalf of these victims. A request was made to the Palm Beach County Sheriff's Office ("PBSO") that it notify the U.S. Attorney's Office of Epstein's release so that further release notification could be made, but PBSO did not honor that request. 3. The right not to be excluded from public court

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

ove and beyond on behalf of these victims. A request was made to the Palm Beach County Sheriff's Office ("PBSO") that it notify the U.S. Attorney's Office of Epstein's release so that further release notification could be made, but PBSO did not honor that request. 3. The right not to be excluded from public court

was bound by its judicial admission that Dr. Jackson was an employee of the United States. Id. at *5. EFTA00208531 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 appear

at 27-32.) With regard to the report of the meeting with Jane Doe #1, the government informed the Court that no report was ever prepared. (DE22.) FSThe United States did not have the opportunity to respond regarding the Order to Show Cause for Lack of Prosecution. F6Fed. R. Crim. P. 60 was adopted on April 23, 2

ove and beyond on behalf of these victims. A request was made to the Palm Beach County Sheriff's Office ("PBSO") that it notify the U.S. Attorney's Office of Epstein's release so that further release notification could be made, but PBSO did not honor that request. 3. The right not to be excluded from public court

of disinterested public officials in the Executive Branch. See U.S. Const. art. II, § 3 (duty to "take Care that the Laws be faithfully executed"); United States'. Armstrong, 517 U.S. 456, 467 (1996) ("power to prosecute" is "one of the core powers of the Executive Branch"). There is no history of "any private

ified which party is misjoined, or which party needs to be joined in order for this CVRA proceeding to properly go forward. With only one defendant, the United States of America, there cannot be any issue regarding severing any claim against a party. On the specific issue of adding a new party, and whether Rule 15 or Rule 21

utilizing the non- prosecution agreement to seek money damages from Epstein. After receiving written notice in January 2009 from the U.S. Attorney's Office of Epstein's guilty pleas and the potential of obtaining compensation from Epstein, Jane Doe No. 3 contacted Robert Josefsberg, Esq., the attorney referenced in

ified which party is misjoined, or which party needs to be joined in order for this CVRA proceeding to properly go forward. With only one defendant, the United States of America, there cannot be any issue regarding severing any claim against a party. On the specific issue of adding a new party, and whether Rule 15 or Rule 21

e act, although within the letter, is not within the intention of the legislature, and therefore cannot be within the statute. Holy Trinity Church I. United States, 143 U.S. 457, 516-17 (1892). In Webb i. United States, 21 CI.Ct. 137 (1990), the Court of Claims was presented with a 17 EFTA00210613 claim for

utilizing the non- prosecution agreement to seek money damages from Epstein. After receiving written notice in January 2009 from the U.S. Attorney's Office of Epstein's guilty pleas and the potential of obtaining compensation from Epstein, Jane Doe No. 3 contacted Robert Josefsberg, Esq., the attorney referenced in

e act, although within the letter, is not within the intention of the legislature, and therefore cannot be within the statute. Holy Trinity Church I. United States, 143 U.S. 457, 516-17 (1892). In Webb I. United States, 21 CI.Ct. 137 (1990), the Court of Claims was presented with a 16 EFTA00210635 claim for

utilizing the non-prosecution agreement to seek money damages from Epstein. After receiving written notice in January 2009 from the U.S. Attorney's Office of Epstein's guilty pleas and the potential of obtaining compensation from Epstein, Jane Doe No. 3 contacted the attorney referenced in the notification letter,