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

pleadings to defendant Epstein. It should be noted, however, that while Epstein is well aware of this CVRA action, he has chosen not to intervene. CI Fed. R. Civ. P. 24 (providing procedures for intervention). Without intervening in the case, he cannot raise any objections to use of the correspondence

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

pleadings to defendant Epstein. It should be noted, however, that while Epstein is well aware of this CVRA action, he has chosen not to intervene. CI Fed. R. Civ. P. 24 (providing procedures for intervention). Without intervening in the case, he cannot raise any objections to use of the correspondence

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

pleadings to defendant Epstein. It should be noted, however, that while Epstein is well aware of this CVRA action, he has chosen not to intervene. CI Fed. R. Civ. P. 24 (providing procedures for intervention). Without intervening in the case, he cannot raise any objections to use of the correspondence

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

pleadings to defendant Epstein. It should be noted, however, that while Epstein is well aware of this CVRA action, he has chosen not to intervene. CI Fed. R. Civ. P. 24 (providing procedures for intervention). Without intervening in the case, he cannot raise any objections to use of the correspondence