Epstein Secrets

the Court's direction. DATED: March 21.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 Telephone Facsimile Florida Bar No.: E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of L

y on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district court in which a defendant

conference call with you personally so that they could bring their concerns to your attention. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University of Utah• BJE: mwk Enclosures This daytime business addre

which the crime occurred," the CVRA clearly provided for "rights ... that apply before any prosecution is underway." (United States v. BP Products North America, Inc., Criminal No. H-07-434, 2008 WL 501321 at *11 (S.D.Tex. Feb.21, 2008) (emphasis in original), mandamus denied in part, In re Dean, No. 08-201

iding the notice herein. DATED: July 2, 2010 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075

d more severely than a first offender . . . [because] repeated misconduct is more reprehensible than an individual instance of malfeasance." BMW of North America, Inc. I. Gore, 517 U.S. 559, 577 (1996) (supporting citations omitted). In addition, under Rule 404(b), Jane Doe is entitled to offer the evidence

36-KAM Document 48 Entered on FLSD Docket 03/21/2011 Page 41 of 42 DATED: March 21,2011 Respectfully Submitted, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, F.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 and Pro Hoc Vice S.J. Quinney College of Law at the University of Utah

y on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district court in which a defendant

781 scanned and taken to Lea* fog redaction and mailino Public Records Reauest 2010781 received on 6130/10 from Farmer. Jaffe. meissing. Edwards. Fistos & Lehrman. P.L. for copy or 'tittles-Vs Ale Bond tail aedresalk Sublett reigned 07/22/2009 422109._ Qffender Called me_today, Stated it showed his status

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4A01EaOatt €1124611 43 DATED: March 21.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISS1NG, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075

ly on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States I BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district court in which a defendant

/21/2011 Page 41 of 42 DATED: March 21, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075

ely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States' BP Products North America, Inc., the district court reasoned that because § 3771(d)(3) provided for the assertion of CVRA rights "in the district court in which a defendant

the victims have offered. DATED: March 21, 2011 Respectfully Submitted, l Bradley J. Edwards adley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075

ight to approve or disapprove a proposed plea in advance or to participate in plea negotiations." In re Dean on remand as United States tBP Products North America, Inc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009). Instead, "[t]he purpose of the reasonable right to confer is for victims to provide information t

03/21/2011 Page 41 of 42 DATED: Much 21.2011 Respectfully Submitted, s/ Bradley I. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro MX Vice Quinney College of Law at the University of Utah Attorneys for Jane Due 01 and Jane Doe 02 41 EFTA00229

y on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court reasoned that because § 377I(dX3) provided for the assertion of CVRA rights "in the district court in which a defendant i

/2 1/201 1 Page 41 of 42 DATED: Much 21.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSIN0, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Smite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075

ely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States" BP Products North America, Inc., the district court reasoned that because § 3771(dX3) provided for the assertion of CVRA rights "in the district court in which a defendant i