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

y, or property interest implicated in the CVRA, and courts arc hesitant to find that a substantive due process right has been created. See Collins I. City of Harker Heights. Texas, 503 U.S. 115, 5 EFTA00177151 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 6 of 9 125 (19

CTIM JOU .9 9, 2008 PAGE 2 or 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United Stales shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense

of a violation of section 1589, 1590, or 1591 of this chapter may bring a civil action against the perpetrator in an appropriate district court of the United States and may recover damages and reasonable attorneys fees. (b) (1) Any civil action filed under this section shall be stayed during the pendency of

ls for the Eleventh Circuit routinely relies on Black's Law Dictionary for the definition of statutory terms, including in criminal cases. See e.g., United States' Young, 528 F.3d 1294, 1297 n.3 (11th Cir. 2008) (definitions of criminal "complaint" and "indictment"); United States I Brown, 526 F.3d 691, 705 (11

uant to the Florida Public Records Act, Chapter 119, Florida Statutes. The facts in this case are as follows: DER is a Defendant in the case styled United States II. South Florida Water Management District. et al., Case No. 88-1886-CIV- Hoeveler, United States District Court, Southern District of Florida ("U.S.

expand or create an exemption to Florida's public records law. Wait I. Florida Power & Light Co., 372 So. 2d 420 (Fla. 1979); Times Publishing Co. I. City of St. Petersburg, 558 So. 2d 487 (Fla. 2d DCA 1990). Principles of federal preemption under the Supremacy Clause may, in limited circumstances, a

se the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing to discuss petitioners' request for a copy of the non-pros

8, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. Assistant U.S. Attorney SERVICE LIST Jane Does 1 and 2 I. United States Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edward

jury and the causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. I. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial

FILED by /g..3 D.C. JUL 0 9 2008 STEVEN M. LARDAORE CLERK U.S. DIST. CT. S.D. Of FLA. • wee. DECLARATION OF A. MARIE VILLAFARA IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT QF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771 I. I, A. Marie Villafafia, do hereby declare

se the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing to discuss petitioners' request for a copy of the non-pros

jury and the causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. I. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11ffi Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denia

N RE: JANE DOE, Petitioner. FILED by D.C. JUL 0 91008 STEVEN M. LKRIMORE CLERK U.S. Din CT. S.D. OF FLA. • WA B. DECLARATION a IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT cw CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771 I. I, do hereby declare that 1 am a member

of a violation of section 1589, 1590, or 1591 of this chapter may bring a civil action against the perpetrator in an appropriate district court of the United States and may recover damages and reasonable attorneys fees. (b) (1) Any civil action filed under this section shall be stayed during the pendency of

expand or create an exemption to Florida's public records law. Wait I. Florida Power & Light Co., 372 So. 2d 420 (Fla. 1979); Times Publishing Co. I. City of St. Petersburg, 558 So. 2d 487 (Fla. 2d DCA 1990). Principles of federal preemption under the Supremacy Clause may, in limited circumstances, a