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efta-efta00205987DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

Date
Unknown
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DOJ Data Set 9
Reference
EFTA 00205987
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2
Persons
3
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant. UNOPPOSED MOTION OF PROPOSED INTERVENORS FOR A ONE-WEEK EXTENSION OF TIME To FILE ADDITIONAL BRIEFING Following the hearing on August 12, 2011, the Court gave proposed intervenors Black, Weinberg, and Lefkowitz until Friday, August 26 to file supplemental briefing on the issues raised concerning plea negotiations with Jeffrey Epstein. Also following the hearing, the decision was made for Mr. Epstein to file a motion seeking limited intervention so that there are no procedural issues regarding whether the protections and policies relating to Federal Rules of Evidence 410 and 408 should be fully considered by the Court in determining whether to grant or deny the plaintiffs' discovery requests for plea negotiation correspondence between Mr. Epstein's lawyers and the U.S. Attorney's Office. We intended

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant. UNOPPOSED MOTION OF PROPOSED INTERVENORS FOR A ONE-WEEK EXTENSION OF TIME To FILE ADDITIONAL BRIEFING Following the hearing on August 12, 2011, the Court gave proposed intervenors Black, Weinberg, and Lefkowitz until Friday, August 26 to file supplemental briefing on the issues raised concerning plea negotiations with Jeffrey Epstein. Also following the hearing, the decision was made for Mr. Epstein to file a motion seeking limited intervention so that there are no procedural issues regarding whether the protections and policies relating to Federal Rules of Evidence 410 and 408 should be fully considered by the Court in determining whether to grant or deny the plaintiffs' discovery requests for plea negotiation correspondence between Mr. Epstein's lawyers and the U.S. Attorney's Office. We intended to file Mr. Epstein's motion to intervene by the Court's deadline of August 26, 2011. We now anticipate that our office will be closed all day Thursday due to Hurricane Irene, and our office may be closed part of the day Wednesday as well. We won't know until after Irene arrives whether our office will be closed on Friday as well. With these time limitations, we will not be able to file our papers as well as Mr. Epstein's motion to intervene and supporting memorandum by the EFTA00205987 present deadline of August 26. We have spoke with counsel for Jane Doe 1 and Jane Doe 2 as well as counsel for the government, and all have stated that they do not object to the extension of time requested here. Accordingly, we respectfully request an extension of time until Friday, September 2, 2011, to file the supplemental briefing of proposed intervenors Black, Weinberg & Lefkowitz, and to file a motion for limited intervention to assert rights under Rules of Evidence 408 and 410. We certify that on August 22, 2011, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN Miami, Florida 33131 By /S/ ROY BLAC ES . Florida Bar N JACKIE PERCZEK, ESQ. Florida Bar No 2 EFTA00205988

Related Documents (6)

DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 58

Case 9:08-cv-80736-KAM Document 58 Entered on FLSD Docket 04707/2011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 AND #2, Petitioners, UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE IN OPPOSITION TO JANE DOES #1 AND #2'S MOTION TO HAVE THEIR FACTS ACCEPTED BECAUSE OF THE GOVERNMENT'S FAILURE TO CONTEST ANY OF THE FACTS IDE491 The United States, by and through the undersigned, hereby opposes Petitioners' Motion to have their "Statement of Undisputed Material Facts" accepted as true [DE49]. Petitioners argue that the Court should accept their Statement as true, despite its conclusory allegations and internal inconsistencies, solely because of the United States' failure to stipulate to the Statement. The Court should deny the motion because: (1) Petitioners have misstated that United States' efforts at reaching agreement on the Statement; (2) the "Undisputed Material Facts" are irre

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DOJ Data Set 9OtherUnknown

CM/ECF - Live Database

CM/ECF - Live Database r Page 1 of 3 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80736-KA M Doe'. United States of America Assigned to: Judge Kenneth A. Marra Cause: no cause specified Date Filed: 07/07/2008 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant LRJ Date Filed # Docket Text 07/07/2008 1 EMERGENCY PETITION for Victim's Enforcement of Crime Victim's Rights Act 18 USC 3771 against United States of America Filing fee $ 350. Receipt#: 724403, filed by Jane Doe. (rb) (Entered: 07/07/2008) 07/07/2008 2 CERTIFICATE OF EMERGENCY by Jane Doe re 1 Complaint (rb) (Entered: 07/07/2008) 07/07/2008 3 ORDER requiring U.S. Attorney to respond to 1 Complaint filed by Jane Doe by 5:00 p.m. on 7/9/08. Signed by Judge Kenneth A. Marra on 7/7/08. (ir) (Entered: 07/07/2008) 07/09/2008 4 NOTICE of Attorney Appearance by Dexter Lee on behalf of United States of America (

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM

Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. VICTIM'S MOTION TO UNSEAL NON-PROSECUTION AGREEMENT COMES NOW the Petitioners, Jane Doe #1 and Jane Doe #2, by and through their undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 ("CVRA"), and file this motion to unseal the non-prosecution agreement that has been provided to their attorneys under seal in this case. The agreement should be unsealed because no good cause exists for sealing it. Moreover, the Government has inaccurately described the agreement in its publicly-filed pleadings, creating a false impression that the agreement protects the victims. Finally, the agreement should be unsealed to facilitate consultation by victims' counsel with others involved who have

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S INITIAL DISCLOSURES Respondent United States of America, by and through its undersigned counsel, makes its Initial Disclosures, pursuant to Fed.R.Civ.P. 26(a)(1)(A), and state: Fed.R.Civ.P. 26(a)(1)(A)fil: 1. R. Alexander Acosta Dean, School of Law Florida International University Rafael Diaz-Balart Hall 11200 S.W. 8'h Street Miami, Florida 33199 (305) 348-1118 Dean Acosta was the United States Attorney, Southern District of Florida, during the time when the criminal investigation of Jeffrey Epstein was opened in the U.S. Attorney's Office, and the non-prosecution agreement was negotiated. 2. was the First Assistant U.S. Attorney in the U.S. Attorney's Office, during the time when the criminal investigation of Jeffrey Epstein was opened, and the non-prosecution agreement was negot

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 290 Entered on FLSD Docket 01/20/2015 Page 1 of 14

Case 9:08-cv-80736-KAM Document 290 Entered on FLSD Docket 01/20/2015 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S OPPOSITION TO JANE DOE #3 AND JANE DOE #4'S CORRECTED MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION Respondent United States, by and through its undersigned counsel, files its Opposition to Jane Doe #3 and Jane Doe #4's Corrected Motion pursuant to Rule 21 for Joinder in Action (D.E. 280), and states: I. PETITIONERS' MOTION TO ADD TWO ADDITIONAL PARTIES SHOULD BE DENIED AS UNTIMELY This action was commenced by Jane Doe #1 on July 7, 2008 (D.E. I). The Court ordered the Government to file a response by July 9, 2008, which was done. On July 11, 2008, the Court held a hearing on the emergency petition. At that hearing, Jane Doe #2 was added to the petition. Now, over six years into the litigation, petitio

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