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

tfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4i° Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: de,: ter. lec(k usdoi.gov Attorney for Respondent CERTIFICATE OF SERVIC

ired by ¶8 of the NPA? 6. Whether damages are to be awarded based on injury to a plaintiff or based on the number of separately proven claims, see United States'. Raker, 2009 WL 4572785 (E.D.Tex., 2009) where the Court rejected the contention that damages were to be allocated per violation? We are not askin

s a victim of one or more offenses enumerated in 18 . § 2255, and, as such, asserts a cause of action against Defendant pursuant to this Section of the United States Code. 30. As a direct and proximate result of the offenses enumerated in 18 . § 2255 being committed against the then minor Plaintiff by Defendan

Attorney 99 N.E. 4° Street Miami, FL 33132 BLACK SREBNICK KORNSPAN &STUMPF =PA.= March 5, 2010 , Esq. Assistant United States Attorney 99 N.E. 4i° Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA-NADER KATHLEEN P. PHILUPS AARON ANTHON MARCOS BEATON, JR. MATTHEW

t at the time of the offense (e.g., 2004-5) govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States'. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)

ttorney 99 N.E. 4th Street Miami, FL 33132 BLACK SREBNICK KORNSPAN & STUMPF =PA.= March 5, 2010 , Esq. Assistant United States Attorney 99 N.E. 4i° Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSIC.A ForisEC-A-NADER ICATEazur P. PHILLIPS AARON AMMON MARCOS BEATON, JR. MATT