Epstein Secrets

Marra on 7/7/08. (ir) (Entered: 07/07/2008) 07/09/2008 4 NOTICE of Attorney Appearance by Dcxtcr Lee on behalf of United States of America (Lee, Dexter) (Entered: 07/09/2008) EFTA00177337 Case 9:08-cv-8( giao8-aaestowseit 1AQof: Clintift200t611LS0DPaildirEttf07 ,37.)8 Page 2 of 2 07/09/2008 6

e not been violated. Therefore, her emergency petition should be denied. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4' Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: clexter.lee@usd

tioner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense" 18 U.S.C. § 3553(aX2)(A). The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States I O

the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafarla Assistant U.S. Attorneys 5

/2011 Page 6 of 25 historically had broad authority to fashion equitable remedies . . . ." Hardison v. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004). The Eleventh Circuit has expressly required district courts to fashion appropriate equitable remedies when plaintiffs have proven a violation of statutory provisions. S

400 West Palm Beach, FL 33401 Telephone: 561-820-8711 Facsimile: 561-820-8777 Email: [email protected] Attorney for United States Dexter A. Lee United States Attorney's Office 99 N.E. 4th Street Miami, FL 33132 Telephone: 305-961-9320 Facsimile: 305-530-7139 Email: [email protected] E

7 of 9 at the insistence of the U.S. Attorney's Office. There is no reason to dismiss the case precipitously now on the eve of a final resolution. The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a cle

Doe #2 7 EFTA00206687 CERTIFICATE OF SERVICE Dexter Lee Epstein through current counsel. 8 EFTA0020668

is matter to a final conclusion in the next few months. There is no reason to dismiss the case precipitously now on the eve of a final resolution. The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a cle

tion. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafaiia A. MARIE VILLAFAIZIA Florida Bar No. 0018255 DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. Street Miami, Florida 33132 Attorney for Respondent 6 EFTA00601813 Case 9:08-cv-80736-

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00601808 Case 9:08-cv-80736-KAM Documen

ent and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. is/Dexter . Lee 31 EFTA00211748 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. ~It Paul G. Cassell Pro Hac

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire I. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

West Palm Beach, FL 33401 Telephone: 561-820-8711 Facsimile: 561-820-8777 Email: [email protected] 9 Attorney for United States Dexter A. Lee United States Attorney's Office 99 N.E. 4th Street Miami, FL 33132 Telephone: 305-961-9320 Facsimile: 305-530-7139 Email: [email protected] E

of 9 at the insistence of the U.S. Attorney's Office. There is no reason to dismiss the case precipitously now on the eve of a final resolution. The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a cle

ent and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 31 EFTA00799855 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 32 of 3

bits "parties from deliberately changing positions according to the exigencies of the moment." New Hampshire v. Maine, 532 U.S. 742, 749-50 (2001). The Eleventh Circuit has identified three factors to be considered in determining whether to apply the equitable doctrine: (1) whether there is a clear inconsistency bet

uction. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafaiia A. MARIE VILLAFARA Florida Bar No. 0018255 DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4th Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexter.lee@usd

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00660795 Case 9:08-cv-80736-KAM Documen

West Palm Beach, FL 33401 Telephone: 561-820-8711 Facsimile: 561-820-8777 Email: [email protected] 9 Attorney for United States Dexter A. Lee United States Attorney's Office 99 N.E. 4th Street Miami, FL 33132 Telephone: 305-961-9320 Facsimile: 305-530-7139 Email: [email protected] E

of 9 at the insistence of the U.S. Attorney's Office. There is no reason to dismiss the case precipitously now on the eve of a final resolution. The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a cle