Epstein Secrets

ehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] 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

ne 29, 2007) ("Federal district court judge Paul Cassell initiated the process [of incorporating the CVRA

A Case No. 08-80736-CIV-MARRA/JOHNSON EFTA00208063 Case 9:08-cv-80736-KAM Document 57-1 Entered on FLSD Docket 04/07/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2n° Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c

ne 29, 2007) ("Federal district court judge Paul Cassell initiated the process [of incorporating the CVRA

tates 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 Salt Lake City, Utah 84112 Attorneys for Jane Doe # 1 and Jane Doe # 2 Since no criminal case was pending, the

ment that a victim be "directly and proximately harmed" encompassed the traditional "but for" and proximate cause analyses. Id. at 350, citing In Re Rendon Galvis , 564 F.3d 170, 175 (2 ' Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the

s, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Fax: E-mail: Attorneys for Jane Doe # 1 and Ja

ne 29, 2007) ("Federal district court judge Paul Cassell initiated the process [of incorporating the CVRA

mate cause analyses. Id. at 350, citing 27 EFTA00078861 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2nd Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c

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 Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile:

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

ate cause analyses. Id. at 350, citing 27 EFTA00177077 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (20° Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the

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.")

, citing 27 EFTA00230092 ff ell.;;;;;:t; --- ------- 1 Case 9:O8-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 28 of 54 In Re Rendon Galvis, 564 F.3d 170, 175 (2gd Cir. 2009). As applied to McNulty, the issue was whether he was directly and proximately harmed by criminal conduct in the c