Epstein Secrets

MCCLOSKEY,MICHAEL LA RENAISSANCE #1 DONNELL,MAUREEN EDGEWATER HOUSE TOLL,WILLIA

QUINN,OLIVER H LOCKER,NANCY OWEN,JANE D CUSHMAN & WAKEFIELD KELLER,MICHAEL

th the federal courts. Furthermore, there is a presumption of concurrent jurisdiction of state courts. See generally, Yellow Freight System, Inc. v. Donnelly, 494 U.S. 820, 823, 110 S.Ct. 1566, 1568-69 (1990). "Under our 'system of dual sovereignty, we have consistently held that state courts have inhere

of sexual exploitation and abuse. In the Jane Doe II state action, an Order was entered reassigning the state action to a Division in which other Jane Doe cases against EPSTEIN had been filed. See "Clerk's Notice Of Reassignment," dated April 10, 2009, and attached hereto as Exhibit B. The state court

th the federal courts. Furthermore, there is a presumption of concurrent jurisdiction of state courts. See generally, Yellow Freight System, Inc. v. Donnelly, 494 U.S. 820, 823, 110 S.Ct. 1566, 1568-69 (1990). "Under our 'system of dual sovereignty, we have consistently held that state courts have inhere

ould ultimately result in reversible error at any trial. II. Conclusion and Prayer for Relief 22. Epstein requests the following relief: a. That JANE DOE's Motion to Proceed Anonymously be denied; b. That this Court grant Epstein's Motion and that JANE DOE be identified by her legal name in the style

preclusion of all documents and discussion of the Jane Doe 102 case, including the settlement of those claim

seneesessens smusanssomneasecceeumesvs 35 Doddy v. Oxy USA, Inc., 101 F.3d 448, 459-60 (Sth Cir. 1996)... ce ceeceseeeseeseeeseeeseeeseeseeeneeees 10 Donnelly v. DeChristoforo, 416 U.S. 637, 646-47, 94 S.Ct. 1868, 40 L.Ed.2d 431 (1974). ....... 33 Edwards y. City of N.Y., No. 08-2199 TLM, 2011 WL 2748665, a

ceceseccecusececusseccsssecesssseescsseeeceseesenssseeestsssessnsaseess 25 17. The Parties agree to preclusion of all documents and discussion of the Jane Doe 102 case, including the settlement of those claims (Motion in Limine 17) ................0005 26 18. The Cassell/Edwards v. Dershowitz litigation is

)... ccc cece cece cs eeteeeteeeeeeseseenaee 35 Doddy v. Oxy USA, Inc., 101 F.3d 448, 459-60 (Sth Cir, 1996)... ccccceceseeeeeeteeteesenseteneeees 10 Donnelly v. DeChristoforo, 416 U.S. 637, 646-47, 94 S.Ct. 1868, 40 L.Ed.2d 431 (1974). ....... 33 Edwards v. City of N.Y., No. 08-2199 TLM, 2011 WL 2748665, a