Epstein Secrets

tted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11'" Cir. 2003). Each of these four factors is easily met here. First, the Government made statements to the victims that induced r

tted, pi Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, & LEHRMAN. P.L. and Paul G.

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00208406 Case 9:08-cv-80736-KAM Document 48 Entered on F

nt did not use "its `best efforts' to protect the rights of [Jane Doe No. 1] (and the other victims) in this case when it failed to confer with her Farmer, Jaffe, Weissing, Edwards, Fistos ft Lehrman, P.L. 425 North Andrews Avenue • Suite 2 • Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11a ' Cir. 2003). Each of these four factors is easily met here. 33 EFTA00210822 Case 9:08-cv-80736-KAM Document 48 Entered on F

tted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS. FIST LEHRMAN. P.L.

ence with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States. McCorkle, 321 F.3d 1292 (11'" Cir. 2003). Each of these four factors is easily met here. First, the Government made statements to the victims that induced r

2 DATED: March 21,2011 Respectfully Submitted, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, F.L

ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00079025 Case 9:08-cv-80736-KAM Document 48 Entered on FL

tted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISS1NG, EDWARDS, FISTOS & LEHRMAN, P.L

nce with regard to the acts, Conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States'. McCorkle, 321 F.3d 1292 (I l" Cir. 2003). Each of these four factors is easily met here. 33 EFTA00185041 Case 90B-cava7236-11CMil Banuarand 3162- etas* R

tted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

ence with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States' McCorkle, 321 F.3d 1292 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00177041 Case 9:08-cv-80736-KAM Document 48 Entered on F

tted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSIN0, EDWARDS, FISTOS & LEHRMAN, P.L

ement barring federal prosecution of their oases because of a deliberate decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorkle, 321 F.3d at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights Act does not apply to this case. IL THE COU

tted, s/ Bradley I. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

ement barring federal prosecution of their oases because of a deliberate decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorkle, 321 F.3d at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights Act does not apply to this case. IL THE COU