Skip to main content
Skip to content
Case File
efta-efta00208161DOJ Data Set 9Other

Case 9:08-cv-80736-KAM Document 128 Entered on FLSD Docket 12/05/2011 Page 1 of 3

Case 9:08-cv-80736-KAM Document 128 Entered on FLSD Docket 12/05/2011 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Joluison JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S PROTECTIVE MOTION FOR REMEDIES COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file this protective motion for remedies for violations of their rights under the Crime Victims' Rights Act. In their concurrently-filed response to the Government's motion to dismiss and sealed response to the Government's motion to dismiss, the victims' outline numerous remedies that would be proper once they prove the Government violated the CVRA. At various points in its earlier pleadings, however, the Government seems to contend that the fact that the victims have not formally filed a motion asserting each and every one of these specific remedies may have some significance in

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00208161
Pages
3
Persons
2
Integrity

Summary

Case 9:08-cv-80736-KAM Document 128 Entered on FLSD Docket 12/05/2011 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Joluison JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S PROTECTIVE MOTION FOR REMEDIES COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file this protective motion for remedies for violations of their rights under the Crime Victims' Rights Act. In their concurrently-filed response to the Government's motion to dismiss and sealed response to the Government's motion to dismiss, the victims' outline numerous remedies that would be proper once they prove the Government violated the CVRA. At various points in its earlier pleadings, however, the Government seems to contend that the fact that the victims have not formally filed a motion asserting each and every one of these specific remedies may have some significance in

Tags

eftadataset-9vol00009

Ask AI About This Document

0Share
PostReddit
Review This Document

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
Case 9:08-cv-80736-KAM Document 128 Entered on FLSD Docket 12/05/2011 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Joluison JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S PROTECTIVE MOTION FOR REMEDIES COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file this protective motion for remedies for violations of their rights under the Crime Victims' Rights Act. In their concurrently-filed response to the Government's motion to dismiss and sealed response to the Government's motion to dismiss, the victims' outline numerous remedies that would be proper once they prove the Government violated the CVRA. At various points in its earlier pleadings, however, the Government seems to contend that the fact that the victims have not formally filed a motion asserting each and every one of these specific remedies may have some significance in this case. The Government also inaccurately describes the remedies the victims are seeking. As the Court is aware, this case presents various issues of first impression and the procedures that the crime victims should follow to protect their CVRA rights are not clearly established. Accordingly, to protect their right to seek all of the remedies they are seeking, the victims protectively file this motion asking the Court to award all these remedies that they I EFTA00208161 Case 9:08-cv-80736-KAM Document 128 Entered on FLSD Docket 12/05/2011 Page 2 of 3 outline in their responses to the motion to dismiss. The Court should award all of these remedies to the victims for the reasons explained in their pleadings and because these remedies address the Government's violations of their rights. DATED: December 5. 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 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 Attorneys for Jane Doe #1 and Jane Doe #2 2 EFTA00208162 Case 9:08-cv-80736-KAM Document 128 Entered on FLSD Docket 12/05/2011 Page 3 of 3 CERTIFICATE OF SERVICE The foregoing document was served on December 5, 2011, on the following using the Court's CM/ECF system: 3 EFTA00208163

Technical Artifacts (1)

View in Artifacts Browser

Email addresses, URLs, phone numbers, and other technical indicators extracted from this document.

Case #9:08-CV-80736-KAM

Related Documents (6)

DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 50

Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

15p
DOJ Data Set 9OtherUnknown

Case 9:08-cv-80893-KAM Document 217 Entered on FLSD Docket 09/13/2010 Page 1 of 7

7p
DOJ Data Set 10CorrespondenceUnknown

EFTA Document EFTA01660111

0p
Court UnsealedJun 16, 2023

Deutsche Bank Epstein victim questionnaire

EXHIBIT A-1 Case 1:22-cv-10018-JSR Document 90-2 Filed 06/16/23 Page 1 of 12 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Case No. 1:22-CV-10018 (JSR) NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION TO: ALL VICTIMS OF JEFFREY EPSTEIN’S SEX TRAFFICKING VENTURE DURING THE TIME PERIOD AUGUST 19, 2013 TO AUGUST 10, 2019 (THE “CLASS PERIOD”). IN ORDER TO QUALIFY FOR A SETTLEMENT PAYMENT, YOU (OR CLASS COUNSEL ON YOUR BEHALF) MUST TIMELY SUBMIT A TIER ONE FORM BY ___________, 20

12p
DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 50

Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372172011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

15p
DOJ Data Set 9OtherUnknown

Subjec

Fr • < > Subjec :Deliberative t Process ec aratton rom am Justice - equest or wo ee xtension Date: Fri, 20 Sep 2013 17:59:47 +0000 Importance: Normal We have no objection, provided we get the following accommodation, which you already anticipated. We would request that your motion for extension of time give us an extension on our reply document, such that our reply would be due 10 days after the main Justice Department declaration that will be coming in two weeks. If you would include such language as well in any proposed order, saving us (and the court) drafting time, that would be very much appreciated. Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2 Paul G Cassell CONFIDENTIAL: This electronic message along with any/all attachments is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message

2p

Forum Discussions

This document was digitized, indexed, and cross-referenced with 1,500+ persons in the Epstein files. 100% free, ad-free, and independent.

Support This ProjectSupported by 1,550+ people worldwide
Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.