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

ecrecy. This attorney could neither confirm nor deny the information presented by the 'external party!" Senate of the Commonwealth of Puerto Rico'. United States Dept of Justice, 1992 WL 119127 at *3 (D.D.C. May 13, 1992) (citing Barry United States, 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(c) does not create a type of se

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

the petition has been filed." 23 EFTA00177073 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 24 of 54 In Sieverding United States Dept of Justice, 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to

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

crecy. This attorney could neither confirm nor deny the information presented by the 'external party.'" Senate of the Commonwealth of Puerto Rico'. United States Dept of Justice, 1992 WL 119127 at '3 (D.D.C. May 13, 1992) (citing Bony. United States, 740 F. Supp. 888, 891 (D.D.C. 1990) ("Rule 6(e) does not create a type of

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

ntence reduction violated his right under the CVRA to be treated with fairness. See id. , 338 Fed. Appx. at 113-14. EFTA00208525 In Sieverding v. United States Dept of Justice , 693 F. Supp. 2d 93 (D.D.C. 2010), the district court discussed a series of claims brought by the Sieverdings, a husband and wife so well known to

ning why those categories of records do not contain reasonably segregable non-exempt information. See, e.g., Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm 'n, No. 3:14-CV-2197, 2016 WL 950995, at *9 (M.D. Tenn. Mar. 12, 2016) (citing examples). Moreover, nonexempt portions of documents m

by the attorney-client privilege, as indicated on the FBI index. This group of emails consists of communications between FBI employees and Assistant United States Attorneys in the Civil Division of the USAO-SDNY, which provided details the AUSA could use in the indictment of Jeffrey Epstein. Seidel Decl. . As

provided information under an express assurance of confidentiality or in circumstances from which such an assurance could be reasonably inferred.'" United States Dept of Justice v. Landano, 508 U.S. 165, 165 (1993). The promised confidentiality can only be waived by the source. Adamowicz v. IRS, 402 Fed. App'x 648, 653 (2d