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efta-efta00235194DOJ Data Set 9Other

Case 9:08-cv-80736-KAM Document 46

Case 9:08-cv-80736-KAM Document 46 Entered on FLSD Docket 03/18/2011 Page 1 of 4 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 UNOPPOSED MOTION FOR FILING OVERLENGTH STATEMENT OF FACTS IN SUPPORT OF THEIR MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for permission to file an overlength statement of facts in support of their soon-to-be-filed motion asking for a finding from this Court that the victims' rights under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office. The motion for permission to file is unopposed. As the Court is aware, the victims and the Government have been engaged in extensive discussions in an effort to resolve this case, or at least narrow the fac

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DOJ Data Set 9
Reference
EFTA 00235194
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4
Persons
2
Integrity

Summary

Case 9:08-cv-80736-KAM Document 46 Entered on FLSD Docket 03/18/2011 Page 1 of 4 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 UNOPPOSED MOTION FOR FILING OVERLENGTH STATEMENT OF FACTS IN SUPPORT OF THEIR MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for permission to file an overlength statement of facts in support of their soon-to-be-filed motion asking for a finding from this Court that the victims' rights under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office. The motion for permission to file is unopposed. As the Court is aware, the victims and the Government have been engaged in extensive discussions in an effort to resolve this case, or at least narrow the fac

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Case 9:08-cv-80736-KAM Document 46 Entered on FLSD Docket 03/18/2011 Page 1 of 4 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 UNOPPOSED MOTION FOR FILING OVERLENGTH STATEMENT OF FACTS IN SUPPORT OF THEIR MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for permission to file an overlength statement of facts in support of their soon-to-be-filed motion asking for a finding from this Court that the victims' rights under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office. The motion for permission to file is unopposed. As the Court is aware, the victims and the Government have been engaged in extensive discussions in an effort to resolve this case, or at least narrow the factual issues in dispute. On March 15, 2011, however, the victims received a letter from the U.S. Attorney's Office rejecting the victims' proposal for narrowing the dispute. The letter also indicated that the U.S. Attorney's Office would not be stipulating to any proposed facts offered by the victims. The victims are now finalizing a comprehensive motion (in the nature of a summary judgment motion) that would ask this Court to find that the U.S. Attorney's Office has violated EFTA00235194 Case 9:08-cv-80736-KAM Document 46 Entered on FLSD Docket 03/18/2011 Page 2 of 4 their rights under the CVRA. The factual predicate for the victims' argument is extensive and includes many e-mails documenting discussions between the U.S. Attorney's Office and defense counsel regarding whether to notify victims of events in the case and how to prevent disclosure of the existence of the non-prosecution agreement signed by the parties. The facts surrounding the concealment of the non-prosecution agreement extend over nearly one year, from roughly September 2007 through July 2008. A full recitation of the facts will take approximately 18 pages, which exceeds the 10-page limit for a summary judgment motion specified in Local Rule 7.5(c)( I). Because the U.S. Attorney's Office has refused to stipulate to any of the victims' facts, the victims are uncertain as to which facts may ultimately end up in dispute. Accordingly, the victims are reluctant to attempt to further shorten their factual accounting at this time. The victims currently hope to file their motion on Monday, March 21, 2011, along with several other associated pleadings. The Government does not oppose this motion. A proposed order is attached along with this motion. WHEREFORE, the victims ask this Court for permission to file an overlength statement of facts totaling approximately 18 pages in support of their motion for finding violations of the Crime Victims' Rights Act. EFTA00235195 Case 9:08-cv-80736-KAM Document 46 Entered on FLSD Docket 03718:2011 Page 3 of 4 DATED: March 18. 201 1 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. AFC AT t. A I A C... n and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 EFTA00235196 Case 9:08-cv-80736-KAM Document 46 Entered on FLSD Docket 03)18.2011 Page 4 of 4 CERTIFICATE OF SERVICE The foregoing document was served on March 18, 2011. on the following using the Court's CM/ECF system: Assistant U.S. Attorney 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: [email protected] Attorney for the Government Joseph L. Ackerman, Jr. Joseph Ackerman, Jr. Fowler White Burnett PA courtesy copy EFTA00235197

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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

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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

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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

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Nlatthewman JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. DECLARATION OF IN SUPPORT OF GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR PARTIAL SUMMARY JUDGMENT AND CROSS-MOTION FOR SUMMARY JUDGMENT do hereby declare that I am a member in good standing of the Bar of the State of Florida. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 2. I am the Assistant United States Attorne

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STATEMENT BY ALAN DERSHOWITZ

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