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Case 9:08-cv-80736-KAM Document 360 Entered on FLSD Docket 02/05/2016 Page 1 of 3

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Case 9:08-cv-80736-KAM Document 360 Entered on FLSD Docket 02/05/2016 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08.80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES NOTICE OF WITHDRAWAL OF JANE DOE NO. 1 AND JANE DOE NO. 2'S MOTION FOR DEPOSITIONS OF GOVERNMENT WITNESSES COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to file this notice that, with the agreement of the Government, they are withdrawing motion for court permission to take the depositions of six important Government witnesses in this action (DE 344). The Government has now responded to the motion (DE 359). After receiving the Government's response, victims' counsel and government counsel have conferred and have jointly agreed that it would be most efficient if the victims withdraw their motion at this time. The withdrawal is without prejudice to victims re-filing their motion, if they believe it is necessary, after the Government responds to the victims' soon-to-be-filed summary judgment motion. This will permit the parties to litigate the issue on the need for depositions based on the matters in dispute once the summary judgment and response thereto have been filed. CONCLUSION With the agreement of the Government, the victims are withdrawing their motion for depositions without prejudice to later refiling. DATED: February 5, 2016 I EFTA01081500 Case 9:08-cv-80736-KAM Document 360 Entered on FLSD Docket 02/05/2016 Page 2 of 3 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, ■. And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universit of Utah' Attorneys for Jane Does No. 1, 2, 3 and 4 'This 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 EFTA01081501 Case 9:08-cv-80736-KAM Document 360 Entered on FLSD Docket 02/05/2016 Page 3 of 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on February 5. 2016. on the following using the Court's CM/ECF system: A. Marie Lee veinafana Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Korns an & Stumpf Attorneys for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA01081502

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Case #9:08-CV-80736-KAM

Related Documents (6)

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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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UNITED STATES DISTRICT COURT

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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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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EFTA Document EFTA01735410

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