Epstein Secrets

Law at the 4 EFTA00205230 Case 9:08-cv-80736-KAM Document 85 Entered on FLSD Docket 06)17.2011 Page 5 of 5 University of Utah 332 S. 1400 E. Salt Lake City. 112 Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFICATE OF SERVICE The foregoing document was served on June 17, 2011, on the following using

lt with prosecutors "how the case was being handled before being filed in court . . ." Id. (emphasis added). Senator Kyl then went on to explain how the Fifth Circuit had extended rights to crime victims before the formal filing of charges in In re Dean, 527 F.3d 391 (5th Cir. 2008) — a case the victims cite in t

4-2820 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: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 54 Respondent's Exhibit

tifiable victims and afford the victims of the rights set forth in the CVRA, prior to the actual entry of the guilty plea. Id. at 393. Ultimately, the Fifth Circuit found the district court erred in entering its ex parte order because the fewer than 200 victims "could be easily reached." Id. at 394-95. Additiona

4-2820 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: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 15 EFTA00208105

(5th Cir. 2010) (Fifth Amendment rights of organization were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). 8 EFTA0

4-2820 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: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 10 EFTA00208124

impugn the reputation of Petitioner." Id. at 1107. The Court further ordered that all of the pleadings in the case be sealed. Id. 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 6 EFTA0

nue, 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 841 12 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 15 EFTA00212586

(5th Cir. 2010) (Fifth Amendment rights of organization were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). 8 EFTA0

: 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: 801-585-6833 E-Mail: [email protected]. edu Attorneys for Jane Doe #1 and Jane Doe #2 2 EFTA006058

trial that has prevented him from turning to the pending motion until today. The other of the victims' counsel, Paul G. Cassell, has a brief due in the Fifth Circuit on November 23, 2011, and also long-scheduled vacation the week of Thanksgiving. Accordingly, victims' counsel seek a 10-day extension to Monday, De

nue, 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 Jane Doe # 2 54 EFTA00078888

tifiable victims and afford the victims of the rights set forth in the CVRA, prior to the actual entry of the guilty plea. Id. at 393. Ultimately, the Fifth Circuit found the district court erred in entering its ex parte order because the fewer than 200 victims "could be easily reached." Id. at 394-95. Additiona

4-2820 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: casselp(alaw.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 15 EFTA00184858 Case

(5th Cir. 2010) (Fifth Amendment rights of organization were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner'. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 8 EFTA00

victims.” The victims sought appellate review in the Fifth Circuit.°’ There, the court concurred with the district c

N. Boyce Presidential Professor of Criminal Law, S.J. Quinney College of Law at the University of Utah. ** Associate, Snow, Christensen & Martineau (Salt Lake City, Utah). *** Partner, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman (Fort Lauderdale, Fla.). The authors thank Douglas Beloof, Patricia Cassell,

N. Boyce Presidential Professor of Criminal Law, S.J. Quinney College of Law at the University of Utah. ** Associate, Snow, Christensen & Martineau (Salt Lake City, Utah). *** Partner, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman (Fort Lauderdale, Fla.). The authors thank Douglas Beloof, Patricia Cassell,

before charges have been filed, courts have uniformly agreed with the victims’ position. Perhaps the leading case to date to assess this question is the Fifth Circuit's decision in In re Dean. °° There, a wealthy corporate criminal defendant reached a generous plea deal with the Government - a deal that the Governmen