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es: The most recent court decision to carefully review the Justice Department's position is Jane Does #1 and #2 v. United States, No. 08-80736-CIV- MARRA/JOHNSON (S.D. Fla. Sept. 26, 2011). In that case, the court flatly rejected the Department's claim that rights attach only after charges are formall
ly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, the Government has unclean hands for multiple reasons — as argued at length in the victims' summary judgment moti
UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED
Page: EFTA00021442 →rly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, Epstein — a sex offender who worked with the USAO-SDFL to illegally conceal an 47 EFTA00021491 --- PAGE BREAK
Page: EFTA00021492 →UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED
Page: EFTA00022546 →rly and without fraud or deceit as to the controversy in issue." Ellenburg v. Brockway, Inc., 763 F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson v. Yellow Cab Transit Co., 321 U.S. 383, 387 (1944)). Here, Epstein — a sex offender who worked with the USAO-SDFL to illegally conceal an 47 EFTA00022595 --- PAGE BREAK
Page: EFTA00022596 →Entities connected to both Kenneth Marra and Yellow Cab Transit Co.

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
United States
LOCATION
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
Jeffrey Sloman
PERSON
the University of Utah
ORGANIZATION
Marc Rich
PERSONthe Eleventh Circuit
ORGANIZATIONGarcia
PERSON
Supreme Court
ORGANIZATION
Michael Cohen
PERSONJacqueline Perczek
PERSON
Maine
LOCATIONWalker
PERSON
Kenna
PERSONU.S. Attorney's Office
ORGANIZATION
Madison
LOCATION