Epstein Secrets

pecialist TOTAL P.O? EFTA00177316 Case 9:08-cv-t -KAM Document 14 Entered on FLSD Docket 07/1 38 Page 18 of 21 U.S. Department of Justice %sr United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach. FL 33401 (361)8204711 Facsimile: (561) 820-8777 Jul

efore the Court on Plaintiff's Emergency Petition for Enforcement of Crime Victim's Rights Act (DE 1), filed July 7, 2008. It is hereby ORDERED that the United States' Attorney shall file a response to this petition by 5:00 P.M. on Wednesday, July 9, 2008. DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach

RT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-C1V-MARRA/JOHNSON 38 Page 1 of 1 ORDER DENYING MOTION TO SEAL THIS CAUSE comes before the Court on the United States of America's Motion to Seal its Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, filed July 9, 2008. The Court has carefully

Government claims is troublesome, the Fifth Circuit cited to the district coirt opinion under review, which had quoted all the words in the statute. See United States'. SP Peoducts, 2008 WL 501321 at *7 (noting victims right to confer "in the case"), cited in In re Dean, 527 F.3d at 394. The Government finally no

VRA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States!. Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing United States" Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but its

of 4 EXHIBIT 116 EFTA00185073 Case 9:08-cv-80736-KAM Document 362-46 Entered on FLSD Docket 02/10/2016 Page 2 of 4 U.S. Department of Justice United Stales Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! July 9, 2008 NOTIFICATION OF IDENTIFIED VIC

0 South Australian Ave., Suite 400 IVest Palm Beach, FL 33401 July 9, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WIT

er a victim under the CVRA. It should be emphasized that the CVRA "was designed to be a `broad and encompassing' statutory victims' bill of rights." United States' 5 EFTA00185058 Case 9:08-cv-80736-KAM rent 362-42 Entered on FLSD cket 02/10/2016 Page 7 of 10 Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah

CVRA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States' Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing United States' Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but its

efore the Court on Plaintiff's Emergency Petition for Enforcement of Crime Victim's Rights Act (DE 1), filed July 7, 2008. It is hereby ORDERED that the United States' Attorney shall file a response to this petition by 5:00 P.M. on Wednesday, July 9, 2008. DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach

Palm Beach County, Florida, this 7th day of July, 2008. KENNETH A. MARRA United States District Judge Copies furnished to: R. Alexander Acosta, United States' Attorney all counsel of record EFTA00177719 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: IN RE: JANE DOE, Petitioner.

RA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States v. Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing United States v. Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but it

thers. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal action to unseal the non-prosecution agreement and addendum (A-3). The United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective

er a victim under the CVRA. It should be emphasized that_the CVRA "was designed to be a 'broad and encompassing' statutory victims' bill of rights." United States' 5 lot 00 EFTA00231181 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 6 of 10 v Degenhardt, 405 F.Supp.2d 1341, 13

RA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States v. Patkar, 2008 WL 233062 at •3 (D. Haw. 2008) (citing United States v. Turner, 367 F.Supp.2d 319, 335 (ED.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but its

and subsequent sexual activity with third parties has no bearing on the issue of whether she consented to or complied with the sexual acts charged. See United States,. Stone, 472 F.2d 909, 919 (5th Cir. 1973); Virgin Islands'. Jacobs 634 F.Supp. 933, 936-37 (D. M. 1986) (policy of rule disallowing evidence to sh

not only the admissibility of evidence at trial, but must also "inform the discovery process." Barta I. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996). The 3 EFTA00222173 Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05;06/2009 Page 4 of 10 Committee Notes state, in releva

d accomplish its purposes and intent"). The CVRA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States'. Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing United States.. Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). Not only must the CVRA as a w

VRA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States'. Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing United States.. Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but its

. (See Reply at 2.) However, in general, "oUr-of-court statements that are offered as evidence of legally operative verbal conduct are not hearsay.' United States v. Pang. 362 F.3d 1187. 1192 (9th Cir. 2004). Because such statements have independent legal significance. they are considered "verbal acts," and ar

ly for the actions of an originator."); Au v. Republic State Mod. Co., No. CIV. 11.00251 JMS, 2012 U.S. Dist. LEAS 106439. 2012 WL 3113147. at '11 (D. Haw. July 31. 2012) ('lAIn assignee cannot be liable for unfair or deceptive acts that may have occurred when loan was consummated. and . . . liability

ing juror sympathy."). Any attempt to encourage such sympathy is therefore an attempt at nullification, which is itself plainly improper. See, e.g., United States v. Thomas, 116 F.3d 606, 615 (2d Cir. 1997) (Jury nullification is "by no means a right or 3 Evidence of the defendant's motive may be relevant evid

United States v. Seltzer, 794 F.2d 1114 (6th Cir. 1986) 28 EFTA00070839 United States v. Shiraishi, No. 17 Cr. 582 (JMS) (RLP), 2019 WL 1386365 (D. Haw. Mar. 27, 2019) 27, 28, 29 United States v. Smith, 148 F. App'x 867 (11th Cir. 2005) 26 United States v. Stroming, 838 F. App'x 624 (2d Cir. 202

thers. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal action to unseal the non-prosecution agreement and addendum (A-3). The United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective

RA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States v. Patkar, 2008 WL 233062 at '3 (D. Haw. 2008) (citing United States v. Turner, 367 F.Supp.2d 319, 335 (ED.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but its