Epstein Secrets

course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney . . . ." Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's Mot. File Supp. Auth. DE #82. Accordingly, an order by this Court making "a specific finding of mis

Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's

Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction. The Court should deny the motion. Because the Government has filed a motion to dismiss alleging that the victims' pleadings are facially deficient

course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney . . . ." Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's Mot. File Supp. Auth. DE #82. Accordingly, an order by this Court making "a specific finding of mis

Letter from Robin C. Ashton to Professor Paul G. Cassell, May 6, 2001, attached as Exhibit 1 to Victim's

Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction. The Court should deny the motion. Because the Government has filed a motion to dismiss alleging that the victims' pleadings are facially deficient

ates District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates. LLC Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney College of Law at the Universit of Utah Salt Lake City, Utah 84112 Attorneys for Jane Doe # 1 and Jane Doe # 2 EFTA00208793

ssociates. LLC Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney College of Law at the Universit of

ing such information be filed under seal. EFTA00208791 WHEREFORE, the United States respectfully requests that the Motion to Dismiss for lack of Subject Matter Jurisdiction be sealed. DATED: November 7, 2011 Respectfully submitted, WIFREDO A. FERRER The undersigned hereby certifies and affirms that a copy of the fore

8/2008) 07/28/2008 16 MOTION for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing for Paul G. Cassell, Filing Fee $75, Receipt #724532. (cw) (Entered: 07/28/2008) 07/29/2008 17 NOTICE by United States of America To Court Regarding Absence of Need

ay C. Howell Jay Howell & Associates PA Paul G. Cassell En e represented by https://ecf.fisd.circll.den

2012 181 Notice of Supplemental Authority in support of Jane Doe #1 and Jan Doe #2's Response to Government's Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction by Jane Doe (Edwards, Bradley) Modified on 12/11/2012 (Is). (Entered: 12/10/2012) 12 21/2012 M RESPONSE in Opposition re M Motion to Expedite Rul

a Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [Service via CM/ECF] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 [Service via CM/ECM Attorneys for Jane Doe # 1

dale, FL 33301-3268 [Service via CM/ECF] Paul G. Cassell S.J. Quinney College of Law at the University o

the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel

stos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [email protected] 954-524-2820 Fax: 954-524-2822 [Service via CM/ECF) Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: cas

Fax: 954-524-2822 [Service via CM/ECF) Paul G. Cassell S.J. Quinney College of Law at the University o

the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel