EFTA00178057Set 9
2011-05-0290p23,378w
Southern District of Florida, . . [the victims] cannot invoke
any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply
irreconcilable with ... pleading to analyze this provision, calling it a
mere "venue provision." Gov't Resp. at 13. But even assuming this a venue provision, the
question remains what is the provision ... claims that Congress "maintained separate legislation aimed at rights
governing pre-charging protections," Gov't Resp. at 19, supposedly found in 42 U.S.C. § 10607.
No court has cited
https://www.justice.gov/epstein/files/DataSet%209/EFTA00178057.pdf
EFTA01098264Set 9
2011-05-0229p9,339w
Southern District of Florida, . . . [the victims] cannot invoke
any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply
irreconcilable with ... pleading to analyze this provision, calling it a
mere "venue provision." Gov't Resp. at 13. But even assuming this a venue provision, the
question remains what is the provision ... claims that Congress "maintained separate legislation aimed at rights
governing pre-charging protections," Gov't Resp. at 19, supposedly found in 42 U.S.C. § 10607.
No court has cited
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098264.pdf
EFTA00207984Set 9
2011-05-0229p9,189w
Southern District of Florida, . . . [the victims] cannot invoke
any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply
irreconcilable with ... pleading to analyze this provision, calling it a
mere "venue provision." Gov't Resp. at 13. But even assuming this a venue provision, the
question remains what is the provision ... claims that Congress "maintained separate legislation aimed at rights
governing pre-charging protections," Gov't Resp. at 19, supposedly found in 42 U.S.C. § 10607.
No court has cited
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207984.pdf
EFTA00205728Set 9
2011-10-1027p8,165w
Government points out, effective defense counsel should always
explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130
S.C.t 1473, 1485 (2010)). But this ... that the Court will need to determine, "on a document-by-
document basis" (Gov't Resp. at I) whether any of the materials in the Government's possession
falls outside ... Procedure, the Government immediately cites the Federal Rules of
Civil Procedural as well. Gov't Resp. at 5 (citing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205728.pdf
EFTA01097994Set 9
2011-10-1027p8,199w
Government points out, effective defense counsel should always
explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130
S.C.t 1473, 1485 (2010)). But this ... that the Court will need to determine, "on a document-by-
document basis" (Gov't Resp. at I) whether any of the materials in the Government's possession
falls outside ... Procedure, the Government immediately cites the Federal Rules of
Civil Procedural as well. Gov't Resp. at 5 (citing
https://www.justice.gov/epstein/files/DataSet%209/EFTA01097994.pdf
EFTA01081982Set 9
2012-04-1927p8,102w
Government points out, effective defense counsel should always
explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130
S.C.t 1473, 1485 (2010)). But this ... that the Court will need to determine, "on a document-by-
document basis" (Gov't Resp. at 1) whether any of the materials in the Government's possession
falls outside ... Procedure, the Government immediately cites the Federal Rules of
Civil Procedural as well. Gov't Resp. at 5 (citing
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081982.pdf
EFTA01202952Set 9
2014-10-2017p4,679w
offenses.
Except as otherwise admitted above, the government denies Request No. 1." Gov't Resp. to
Pet.'s First Request for Admissions, #1 (emphasis added). The Court will also recall ... Admission #4. Rather than admit this
point, the Government flatly denied it. Gov't Resp. to Pet.'s First Request for Admissions, #4.
Motive is clearly in dispute in this ... case and that he learned confidential, non-public information about the case.
Gov't Resp. to Pet.'s First Request for Admissions, #15(a) and #15(b). Clearly the
Government
https://www.justice.gov/epstein/files/DataSet%209/EFTA01202952.pdf
EFTA00208013Set 9
2011-05-0211p3,071w
declined to turn
over to crime victims their own confidential pre-sentencing reports. Gov't Resp. at 3-4. These
cases about judicial obligations say nothing about prosecutorial obligations under ... protected life, liberty, or
property interest," the Due Process Clause is not triggered. Gov't Resp. at 5.
The Government completely misapprehends the victims' position. The victims are not
arguing ... that it is "happenstance" that this
case is opened as a civil matter. Gov't Resp. at 7. But the Government cannot deny that Rule I
of the Federal Rules
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208013.pdf
EFTA01098253Set 9
2011-05-0211p3,206w
declined to turn
over to crime victims their own confidential pre-sentencing reports. Gov't Resp. at 3-4. These
cases about judicial obligations say nothing about prosecutorial obligations under ... protected life, liberty, or
property interest," the Due Process Clause is not triggered. Gov't Resp. at 5.
The Government completely misapprehends the victims' position. The victims are not
arguing ... that it is "happenstance" that this
case is opened as a civil matter. Gov't Resp. at 7. But the Government cannot deny that Rule I
of the Federal Rules
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098253.pdf
EFTA00211035Set 9
2015-12-177p1,552w
arguing that
its FBI agents properly and fully informed the victims. See, e.g., Gov't Resp. to 2d RFA 14(a)
(The Government "denies that, during the period from September ... argument and it properly conferred with
the victims throughout the process. See, e.g., Gov't Resp. to 2d RFA 14(e) (The Government
"denies that, during the period from September
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211035.pdf