Epstein Secrets

ED: Much 21.2011 Respectfully Submitted, s/ Bradley I. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro MX Vice Quinney College of Law at the University of Utah Attorneys for Jane Due 01 and Jane Doe 02 41 EFTA00229957 Case 9:08-cv-80736-KAM

G, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro MX Vice Quinney College of Law at the Univ

sonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

ttorneys. 18. Prior to the filing of Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act, neither Mr. Edwards, nor Judge Cassell, nor anyone on their behalf contacted me to determine if the allegations in Paragraphs 52 and 53 of that Motion were true. I declare under penalty

62 Entered on FLSD Docket 04/08/2011 Page 49 of 54 draft of Rule 60. See 153 Cong. Rec. 58742, S8746 (June 29, 2007) ("Federal district court judge Paul Cassell initiated the process [of incorporating the CVRA into the Federal Rules] by recommending rule changes to the Advisory Committee on Criminal Rules.")

easonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. Dainderarysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could believe that his actions were

075 E-mail: [email protected] and Paul G. Cassell Pro MX Vice S.J. Quinnoy College of Law at the

2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: [email protected] and Paul G. Cassell Pro MX Vice S.J. Quinnoy College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 8

reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

attorneys. 18. Prior to the filing of Plaintiffs Motion for Finding of Violations of the Crime Victims' Rights Act, neither Mr. Edwards, nor Judge Cassell, nor anyone on their behalf contacted me to determine if the allegations in Paragraphs 52 and 53 of that Motion were true. I declare under penalty

62 Entered on FLSD Docket 04/08/2011 Page 49 of 54 draft of Rule 60. See 153 Cong. Rec. 58742, S8746 (June 29, 2007) ("Federal district court judge Paul Cassell initiated the process [of incorporating the CVRA into the Federal Rules] by recommending rule changes to the Advisory Committee on Criminal Rules.")

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan ! DaintlerChrysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could believe that his actions were

tus, E.F. (2000, April) The poet as brain mechanic: A 2050 version of physics for poets. Global Business Network Bulletin, p.1-5. Loftus, E. L. and Castelle, G. (2000) Crashing Memories in Legal Cases. In P.J. van Koppen & N.H.M. Roos (Eds). Rationality, Information and Progress in Law and Psychology. Ma

Roediger, D.L. Schacter & R.F. Thompson (Eds.) Encyclopedia of Learning and Memory. NY:: MacMillan, Vol I. Abelson, R.P., Loftus, E.F. & Greenwald, A.G. (1992) Attempts to improve the accuracy of self-reports of voting. In J.M. Tanur (Ed.) Questions about Questions: Inquiries into the Cognitive Bases