Epstein Secrets

—and we needn't do so even in this case. We cite Professor Cassell's article here (and elsewhere) for several reason

agreement that these "proceeding"-focused rights apply only after the filing of a complaint or criminal charges. See Reply in Supp. of Pet. at 17; Paul G. Cassell, et aL, Crime Picini's' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Criminal Charges Are Filed, 104 J. of

they assert that the term "case" can "refer both to a judicial case before a court and an investigative case pursued by a law enforcement officer," Cassell et al., supra, at 72 (emphasis added).9 Although it's true, at least in the abstract, that the term "case" can mean either thing, in legal parlanc

r, as the CVRA requires, she filed a petition for writ of mandamus. See 18 U.S.C. § 3771(d)(3): see also 16 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 3932 (3d ed. 2019) (explaining that a mandamus petition is "an original application to the court of appeals"). The question before

discussed. Moreover, in an effort to facilitate contact on these issues, the same day that filed his motion to intervene (May 3), victims' counsel (Cassell) sent an e-mail to requesting an opportunity to talk with him about his role in the Epstein case. The next day (May 4), sent a letter back refusin

. DATED: May 17, 2011 7 motion to intervene in Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 EFTA00205017 Joseph L. Ackerman, Jr. Fowler White Burnett PA CERTIFICATE OF SERVICE Th

`satellite litigation"' that will frustrate the rule's goal of 'more effective operation of the pleading regimen.' Id. (citing 5A Wright & Miller, Federal Practice and Procedure § 1332, at 29 (1990)). motion is also untimely. On March 20, 2011, the victims filed their motion for summary judgment — the pleading

. Moreover, in an effort to facilitate contact on these issues, the same day that Reinhart filed his motion to intervene (May 3), victims' counsel (Cassell) sent an e-mail to Reinhart requesting an opportunity to talk with him about his role in the Epstein case. The next day (May 4), Reinhart sent a le

WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 6 EFTA00795279 Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05)16.2011 Page 7 of 8 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFICATE OF SERVICE The foregoi

" `satellite litigation' that will frustrate the rule's goal of `more effective operation of the pleading regimen.' Id. (citing 5A Wright & Miller, Federal Practice and Procedure § 1332, at 29 (1990)). Reinhart's motion is also untimely. On March 20, 2011, the victims filed their motion for summary judgment — t

ge No. 26 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Counsel for Plaintiff Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger

derdale, FL 33301 Counsel for Plaintiff Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101

as a factual allegation"). Factual allegations must be enough to raise a right to relief above the speculative level, see 5 C. Wright & A. Miller, Federal Practice and Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) ("Mlle pleading must contain something more ... than ... a statement o