EFTA00021512.pdf

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Source set: data-set-8
Extracted text

Case 9:08-cv-80736-KAM Document 468 Entered on FLSD Docket 07/24/2019 Page 1 of 5 
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. 
JEFFREY EPSTEIN, 
Limited Intervenor. 
LIMITED INTERVENOR JEFFREY EPSTEIN'S MOTION FOR 
LEAVE TO FILE A REPLY ON OR BEFORE AUGUST 22, 2019 
Limited Intervenor JEFFREY EPSTEIN, through undersigned counsel, respectfully 
moves the Court for an Order granting him leave to file a reply to Petitioners' Reply to 
Intervenor Epstein's Brief in Opposition to Proposed Remedies (DE 466), on or before 
August 22, 2019. 
1. On May 13, 2019, this Court entered an Order (DE 454) setting a briefing 
schedule for the Petitioners to file their initial submission on proposed remedies, 
the government and Mr. Epstein to file a response, and for Petitioners to file a 
reply. 
2. Petitioners filed their initial submission on May 23, 2019 (DE 458), the 
government filed its response on June 24, 2019 (DE 462), Mr. Epstein filed his 
1 
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Case 9:08-cv-80736-KAM Document 468 Entered on FLSD Docket 07/24/2019 Page 2 of 5 
response on July 8, 2019 (DE 463), and Petitioners filed their replies to the 
government and Mr. Epstein's submissions on July 9 & 23, 2019, respectively 
(DE 464; DE 466). 
3. Petitioners' reply to Mr. Epstein's Brief (DE 466) is 65 pages long. In that reply, 
among other things, Petitioners' counsel: 
a) 
raise an issue, for the first time, about the binding nature of the NPA 
on other districts, which is not relevant to the issues before the Court and has 
never been briefed before this Court (DE 466:3-5); 
b) 
rely on sealed documents that Mr. Epstein has never seen (DE 466:19-
23, 48), to argue, for the first time at the remedy phase, that a purported 
conflict of interest that allegedly plagued one of Mr. Epstein's lawyers 
somehow requires partial rescission of the NPA, despite that it is a criminal …
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