Epstein Secrets

Lauderdale, Florida 33301 (954) 524-2820 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 D

anon of statutory construction that "discourages courts from adopting a reading of a statute that renders any part of the statute mere surplusage." Bailey v. United States, 516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous meaning"). Congress i

s daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah. 64 EFTA00799951 Case 9:08-cv-80736-KAM Document 416 Entered on FLSD Docket 08/11/2017 Page 65 of 65 CERTIFICATE OF SERVICE I certify that the

rt its argument, the Government relies on the presumption "that Congress intends to change the law when it enacts amendments." DE 401-2 at 8 (citing Bailey v. United States 52 Fed. Cl. 105, 110 (2002)). According to the Government, the fact that Congress 19 EFTA00799906 Case 9:08-cv-80736-KAM Docume

LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK SREBNICK KORNSPAN & STUMPF 201 S. Biscayne Boulevard, Suite 130

s.... This legislation will help for all of those reasons."). The presumption is that Congress intends to change the law when it enacts amendments. Bailey v. United States, 52 Fed. Cl. 105, 110 (2002), citin Wallace v. Jaffree 472 U.S. 38, 59 n.48 (1985). Here, not only did Congress change the law by c

s daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah 2 EFTA00191399 CERTIFICATE OF SERVICE I certify that the foregoing document was served on January 21, 2015, on the following via US Mail: Dext

— communicate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26th meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — w

ue, Suite 2 Fort Lauderdale, Florida 33301 Tel: E-mail: [email protected] Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 Tel: E-mail: [email protected] Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek BLACK S

s.... This legislation will help for all of those reasons."). The presumption is that Congress intends to change the law when it enacts amendments. Bailey v. United States, 52 Fed. Cl. 105, 110 (2002), citin Wallace v. Jaffree 472 U.S. 38, 59 n.48 (1985). Here, not only did Congress change the law by c

Lehrman, P.L. 425 North Andrews Avenue, 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

anon of statutory construction that "discourages courts from adopting a reading of a statute that renders any part of the statute mere surplusage." Bailey v. United States, 516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous meaning"). Congress i

Lauderdale, Florida 33301 (954) 524-2820 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 D

York and in Florida. Estes stated they travel with Epstein everywhere he goes. I interviewed Zara Bailey of 35 Riverside Jersey City, New Jersey. Bailey stated she just arrived from Scotland and has worked with Zeff for only one month. She stated she has never met Epstein and has not seen him. The i

mile (954) 524-2822 Florida Bar No.: 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] Attorneys for Jane Doe #1

anon of statutory construction that "discourages courts from adopting a reading of a statute that renders any part of the statute mere surplusage." Bailey' United States, 516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous meaning"). Congress int