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URT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United States hereby requests that this Court enter an order dismissing these
nsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have
pstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Ethic., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hombook law that all parties to a contract are necessary in an action challenging its validity ...."); D
URT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United States hereby requests that this Court enter an order dismissing these
nsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have
pstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Ethic., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hombook law that all parties to a contract are necessary in an action challenging its validity ...."); D
URT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION The United States hereby requests that this Court enter an order dismissing these
nsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have
pstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Ethic., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hombook law that all parties to a contract are necessary in an action challenging its validity ...."); D
regarding any of 19 your allegations that are set forth in your complaint 20 directed to Mr. Epstein? 21 A. No. 22 Q. Did you ever speak with a United States -- 23 well, let me strike that. 24 Did you ever speak with an assistant attorney 25 or an attorney from -- who represented him or herself to Pa
s at the time you were living with het? Page 56 1 Q. A few months? 2 A. Yes. 3 Q. What does a few months mean you to? Tine or 4 four, five, Ethic? S A. About three. 6 Q. Did you — and was she -. was she living at 7 the same place in =En 8 A. No. 9 Q. Where was she living at that time?
n criminal cases. See e.g., United States v. Young. 528 F.3d 1294, 1297 n.3 (11th Cir. 2008) (definitions of criminal "complaint" and "indictment"); United States v. Brown, 526 F.3d 691, 705 (11th Cir. 2008) (definition of "knowingly" in criminal statute). A Westlaw search revealed that in 2008 alone, the Elev
when, on the basis of a dispositive issue of law, no construction of the factual allegations will support a cause of action." Marshall County Bd. of Ethic. v. Marshal County Gas Dist., 992 F.2d 1171, 1174 (11th Cir. 1993). "[T]o survive a 2 EFTA00222724 Case 9:08-cv-80119-KAM Document 40 Entered
Entities connected to both United States and Ethic

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Phoenix
LOCATIONthe Southern District
LOCATION
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
Virginia Giuffre
PERSON
Samantha Power
PERSON
Southern District of New York
ORGANIZATION
Paul Cassell
PERSON
A. Marie Villafana
PERSON
the United States District Court
ORGANIZATION
Supreme Court
ORGANIZATIONEmmy Taylor
PERSON