Epstein Secrets

this court enter an order denying the remaining contentions by the defendant in his Motion to Dismiss. Respectfully submitted, /.s/.lack P Frill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 ipley, P.A. West Palm Reach Floriea 33409 Attorneys for Plaintiff EFTA00201226 C

Respectfully submitted, /.s/.lack P Frill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Ba

accorded the clear meaning of the ordinary language terms employed in those provisions." Union of Needle Trades, Industrial and Textiles Employees, AFL-CIO, CLC v. United States Immigration and Naturalization Service, 202 F. Supp. 2d 265, 270 (S.D.N.Y. 2002). Most importantly, courts must give "effect

nvolving two other victims (Dkt 290.1, Dkt 311 at 12), and she was making herself publicly available by giving interviews to the and to Edwards and Scarola in 2011. She was an adult in 2008 (25) and 2011 (28). She has a responsibility to join the lawsuit prior to the completion of JE sentence. Principle

erful people. 50. In around April 2011, as a follow-up to my earlier call with Brad Edwards, I got a telephone call from him and another attorney, Jack Scarola. They just wanted general information about whether various people had information relevant to the lawsuit. They told me that they were taping the

aint seeks to effect a change in the parties to the action, Rule 21 ... controls and, to that extent, limits Rule I5(a)." Intl Broth. of Teamsters'. AFL-CIO, 32 F.R.D. 441, 442 (E.D. Mich. 1963). While the Government cites three cases allowing the addition of new parties through Rule IS (DE 290 at 102).

1, 1 27. In her April 7, 2011 interview with Mr. Scarola, Jane Doe No. 3 stated that she was contacted in

ects the argument made by petitioners that Rule 21 applies because it is more specific. D.E. 310 at 15-16, citin International Broth. of Teamsters'. AFL-CIO 32 F.R.D. 441, 442 (E.D.Mich. 1963). Since it is a precedential decision of the Eleventh Circuit, McLellan is binding authority. Accordingly, if th

1, r 27. In her April 7, 2011 interview with Mr. Scarola, Jane Doe No. 3 stated that she was contacted in

cts the argument made by petitioners that Rule 21 applies because it is more specific. D.E. 310 at 15-16, citing International Broth. of Teamsters'. AFL-CIO, 32 F.R.D. 441, 442 (E.D.Mich. 1963). Since it is a precedent decision of the Eleventh Circuit, McLellan is binding authority. Rule 15 governs peti