Case 9:08-cv-80736-KAM Document 57
Summary
Case 9:08-cv-80736-KAM Document 57 Entered on FLSD Docket 04/07/2011 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE MEMORANDUM OF LAW IN EXCESS OF TWENTY PAGES Respondent, United States, by and through its undersigned counsel, files its Motion for Leave of Court to File Memorandum of Law in Excess of Twenty Pages, and states: I. Under S.D.Fla.L.R. 7.1(c)(2), no party shall file any legal memorandum exceeding twenty (20) pages in length, absent prior permission of the Court. 2. Respondent has prepared its Response to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victims Rights Act and Request for a Hearing on Appropriate Remedies, which numbers fifty-three (53) pages. A copy is attached as Exhibit A. The additional length of the Response was necessary to adequate
Persons Referenced (7)
“...numbering fifty-three (53) pages. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 09...”
Jane Doe #2“...THERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE MEMORANDUM...”
U.S. Attorney“...FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4ih Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-ma...”
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EFTA DisclosureRelated Documents (6)
Farmer, Jaffe, Weissing,
Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti e 6.‘ tk i r atire CalkAllfle alvdtr aIINNEV rar ,NYTTENNINIP PITNEY 'OWES 02 !F $003 , 50 0 000i3V, wit JAN 2i 2,2!3 .a4P En M ZIP t20-12E 3330 Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 EFTA00191396 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT EFTA00191397 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doc No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and Jane Doe No. 4, move to file the attached pleading and supporti
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, UNITED STATES OF AMERICA, Respondent. PARTIES' CONFIDENTIAL JOINT STATUS REPORT The parties, by and through undersigned counsel, hereby file this joint status report on the state of settlement negotiations. In support thereof, the parties state: 1. On May 23, 2016, the parties appeared before the Hon. Dave Lee Brannon for a settlement conference (DE392). Progress was made towards settlement, and it was agreed that the parties would continue working on their own towards settlement and re-convene for a second settlement conference on June 28, 2016 (id.). In accordance with that schedule, U.S. Magistrate Judge Brannon ordered the parties to file a joint status report by noon on June 24, 2016 (DE393), which was later continued to noon on July 1, 2016 (DE395). 2. The parties have continued to discuss the matter and progress continues t
WVVW.PATHTOJUSTICECOM
WVVW.PATHTOJUSTICECOM Oro Tam Class Attie., Personal Injury Wrongful Death Commercial Liogation Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. January 29, 2015 Wilfredo A. Ferrer United States Attorney Southern District of Florida 99 N.E. 4th Street Miami, FL 33132 RE: Jane Does I and 2 v. United States Case No. 9:08-cv-80736-KAM Dear Mr. Ferrer: As you know, we have corresponded with you in the past on the Crime Victims' Rights Act case captioned above. And you met with Jane Doe No. 1 several years ago, promising (as we understood it) to do what could be done to help protect crime victims' rights in this case. It is in that spirit that we are writing to request your assistance on three motions that we are planning to make shortly in this case. We hope that you will be able to agree to all three requests. We will be filing these motions on Friday, February 6, 2015. Accordingly, the favor of a reply by Wednesday, February 4, 2015, is requested. I. Mot
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, 1. UNITED STATES OF AMERICA, Respondent, PARTIES' CONFIDENTIAL JOINT STATUS REPORT The parties, by and through undersigned counsel, hereby file this joint status report on the state of settlement negotiations. In support thereof, the parties state: 1. On May 23, 2016, the parties appeared before the Hon. Dave Lee Brannon for a settlement conference (DE392). Progress was made towards settlement, and it was agreed that the parties would continue working on their own towards settlement and re-convene for a second settlement conference on June 28, 2016 (kl.). In accordance with that schedule, U.S. Magistrate Judge Brannon ordered the parties to file a joint status report by noon on June 24, 2016 (DE393), which was later continued to noon on July 1, 2016 (DE395). 2. The parties have continued to discuss the matter and progress continue
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
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen
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