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

nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers. http://gawker.comM5751094/law--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A

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

nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, hup://gawkencom/#!5751094/law—order-commemorates-jeffity- epsteins-taste-for-teen-hookers. Al

fic discussion of the CVRA and victim notices. All relevant evidence is admissible. See Fed. R. Evid. 402. Relevant evidence is "broadly defined," United States' Glasser, 773 F.2d 1553, 1560 (11th Cir. 1985), as evidence that has "any tendency to make the existence of any fact that is of consequence to the d

nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comW5751094flaw--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A

Circuit has instructed that the district courts must make substantial findings before sealing records in criminal cases before it. For instance, in United States'. Ochoa-Vasque, 428 F.3d 1015 (11ih Cir. 2005), the Eleventh Circuit reversed an order from this Court that had sealed pleadings in a criminal case,

tim Unit devoted an episode to the case, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comM5751094/law--order-commemorates-jeffrey-epsteins-taste-for- teen-hookers.

r showing of a `substantial case on the merits when the balance of the equities weighs heavily in favor of granting the stay.'" DE 206 at 2 (citing United States' Hamilton, 963 F.2d 322 (11th Cir. 1992) (internal quotations omitted)). Citing relevant caselaw, the district court found that Epstein had "neither

Unit devoted an episode to it recently, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jay Epstein Taste for Teen Hookers, http://gawker.comM5751094/law--order- commemorates-jeffrey-epsteins-taste-for-teen-hookers. Also,

fic discussion of the CVRA and victim notices. All relevant evidence is admissible. See Fed. R. Evid. 402. Relevant evidence is "broadly defined," United States' Glasser, 773 F.2d 1553, 1560 (11th Cir. 1985), as evidence that has "any tendency to make the existence of any fact that is of consequence to the d

nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comW5751094flaw--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A

fic discussion of the CVRA and victim notices. All relevant evidence is admissible. See Fed. R. Evid. 402. Relevant evidence is "broadly defined," United States' Glasser, 773 F.2d 1553, 1560 (11th Cir. 1985), as evidence that has "any tendency to make the existence of any fact that is of consequence to the d

nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comW5751094flaw--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A

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

nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, hup://gawkencom/#!5751094/law—order-commemorates-jeffity- epsteins-taste-for-teen-hookers. Al