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is a red herring. Also, the canon of constitutional avoidance does not apply here because the CVRA is plain and unambiguous. See United States v. Stevens 559 U.S. 460, 481, 130 S. Ct 1577, 1591-92, 176 L.Ed.2d 435 (2010) (providing that courts cannot "rely upon the canon of construction that 'ambigu
red the girls for Epstein's sexual gratification or participated in the sexual abuse themselves. The victims include the petitioners in this case, Jane Doe 1 and Jane Doe 2, who were 15 years old when first sexually abused by Epstein. B. Aug. 2006 Letter to Crime Victim about CVRA Rights Throughout the
her statutory rights under the CVRA. For example, in 2006 and before an indictment was drafted in 2007, the U.S. Attorney's Office told petitioner Jane Doe 2 in a letter that she had statutory rights "to confer with the attorney for the Government in the case," "to be treated with fairness," and to petit
MARDER,DR GARY TRAULSEN,REGINE STEVENS,MARK FEDUMA LLC AARON,EUGENE G
QUINN,OLIVER H LOCKER,NANCY OWEN,JANE D CUSHMAN & WAKEFIELD KELLER,MICHAEL
mits of a court's power to enter a judgment can be traced to this Court's early precedents." Libretti v. United States , 116 S.Ct. 356, 371 (1995) (Stevens, J., dissenting). Just as a court's subject matter jurisdiction cannot be conferred by estoppel, Mickler v. Nimishillen and Tuscarawas Railway Co. ,
fforts to comply with the CVRA. (DE 6-8, 12-14.) On July 10, 2008, the Court set the matter for a hearing on July 11, 2008. (DE 5.) At the hearing, Jane Doe #2 was added as a Petitioner. (DE15 at 14.) The Court inquired of Petitioners what remedy they sought, and Petitioners made clear that they wanted t
the relevant federal statutes unambiguously indicate that these statutes were designed to address problems of a national and international Justice Stevens, in his concurring opinion, also acknowled d the rule of lenity, calling the plurality opinion's discussion of that rule "surely persuasive." United
er in the former firm of Herman, , & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled "Jane Doe # vs. Jeffrey Epstein," despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Feder
the relevant federal statutes unambiguously indicate that these statutes wcrc designed to address problems of a national and international Justice Stevens, in his concurring opinion, also acknowledged the Me of lenity, calling the plurality opinion's discussion of that rule "surely persuasive." United
the formcr firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled "Jane Doe # vs. 'effigy Epstein" despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Federa
de to forensic behavioral sciences (2nd ed.; pp. 199-228). Charles C. Thomas. Davis, D. & Loftus, E.F. (2018) Eyewitness Science in the 21' Century. Stevens' Handbook of Experimental Psychology and Cognitive Neuroscience. Vol 1: Learning and Memory. 4th Ed. Wiley 2019 Loftus, E.F. & Teitcher, J. (2019)
Balancing with the players stacked against you. Applied Cognitive Psychology, 16, 365-366 (Book Review). Loftus, E.F. & Guyer, M. (2002) Who Abused Jane Doe?: The Hazards of the Single Case History. Skeptical Inquirer. Part I. Vol 26, #3 (May/June), Pp. 24-32. Loftus, E. F. & Guyer, M. J. (2002) Who Abu
opinion invokes the canon of constitutional avoidance, it does not apply here because there is no ambiguity in the CVRA text. See United States v. Stevens. 559 U.S. 460, 481, 130 S. Ct. 1577. 1591-92. 176 L.Ed.2d 435 (2010) (providing that courts cannot 'rely upon the canon of construction that 'ambig
30 underage girls whom he sexually abused at his mansion in Palm Beach, Florida. The victims la ded one of the initial petitioners in this case, (Jane Doe I), who was 15 years old when Epstein first sexually abused her. Following the FBI's investigation, the U.S. Attorney's Office for the Southern Di
t al. (sadomasochistic sex trafficking) Consultant to the defense in U.S. v. David H. Brooks (white collar crimes) Consultant to the plaintiff in Stevens v. U.S. (anthrax attack) Consultant to the United States Attorney's Office, Tucson, AZ, in U.S. v. Jared Loughner (Tucson mass murder and assassi
k, New York) [2nd Circuit Opinion: 938 F.2d 1535 (2nd Cir. 1991)] Testified at deposition, 5/13/90 Testified in court (trial or hearing), 5/14/90 Jane Doe v. Stuart Brown. M.D. (San Diego, California) Testified by deposition, 6/6/90 Carin Evans vs. Richard Benton, Ph.D. (Houston, Texas) Testified at
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sations about Prof. Dershowitz until a month ago, even though the alleged transgressions supposedly occurred some fifteen years ago. Although neither Jane Doe #3 nor anyone else had previously asserted any improper sexual contact with Prof. Dershowitz, now Jane Doe #3 cynically exploits the yoke of victimhoo
Page: HOUSE_OVERSIGHT_010736 →d liberty...” Krauser v. Evolution Holdings, Inc., 975 F.Supp. 2d 1247, 1260 (S.D. Fla. 2013); quoting Spencer v. Kemna, 523 U.S. 1, 24 n. 5 (1998) (Stevens, J., dissenting). HOUSE_OVERSIGHT_010738 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 5 of 19 In
Page: HOUSE_OVERSIGHT_010739 →f the relevant federal statutes unambiguously indicate that these statutes were designed to address problems of a national and international Justice Stevens, in his concurring opinion, also acknowledged the rule of lenity, calling the plurality opinion’s discussion of that rule “surely persuasive.” United
Page: HOUSE_OVERSIGHT_012146 →in the former firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled “Jane Doe # vs. Jeffrey Epstein,” despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Feder
Page: HOUSE_OVERSIGHT_012167 →Entities connected to both Stevens and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Salt Lake City
LOCATIONSouthern District
LOCATION
Alexander Acosta
PERSONScott Rothstein
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON