Epstein Secrets

the victims have offered. DATED: March 21, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, P.L. ort Lauderdale, Flonda Telephone Facsimile Florida Bar No. E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah

etition, held on July 11, 2008. The Court discussed a need to "hav[e] a complete record, and this is going to be an issue that's ... going to go to the Eleventh Circuit, [so it] may be better to have a complete record as to what your position is and the government's is as to what actions were taken." Tr. at 25-26. C

TTORNEY ATTORNEY TO BE NOTICED Amiens United States of America represented by United States Attorney's Office 500 East Broward Blvd 7th Floor Ft Lauderdale , FL 33394 , ext. 3546 https://ecf.flsd.uscourts.gov/egi-bin/DktRpt.pl?985369616841682-L_801_0-1 6/10/2009 EFTA00175328 CM/ECF - Live Database

0 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote and unlikely"). In discussing Twombly, the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (111h Cir. 2007), noted - "The Supreme Court's most recent formulation of the pleading sp

efendant Rothstein are the sole owners of the equity in the firm. 5. The firm's principal office is located at 401 East Las Olas Blvd, Suite 1650, Fort Lauderdale, FL. 33301. 6. Venue properly lies with this Court because the firm's principal office is in Broward County. BACKGROUND AND GROUNDS FOR DISSOLUTI

L/slm I Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit, Sag Bonner v. City of Prichard, Ala., 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 19439748.2 EFTA00193952 EFTA00193953

205 Biscayne Boulevard Miami, FL 33160 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Adler 18 401 East Las Olas Boulevard Port Lauderdale, FL 33301 19 Jane Doe 3, 4, 5, 6, 7 20 ISIDRO M. GARCIA, ESQ. 21 Garcia Elkins Boehringer 224 Datura Avenue West Palm Beach, FL 33401 22 Ja

ur Office prevails on that issue, the victims would obviously have no claim under the CVRA. The victims would then pursue their appellate rights in the Eleventh Circuit. If, however, the victims prevail on that issue, then your Office would take "no position" on the remedy sought by the victims for the violation of