Subject: RE: Re:
Subject: RE: Re: Date: Mon, 26 Sep 2011 20:02:17 +0000 Importance: Normal Nobody knows. At the very first hearing -- 3 years ago — the judge said the most he could do is order us outside to "confer." Sent: Monday, September 26, 2011 3:56 PM Subject: Re: What if the court disagrees and says we violated cvra - what's the remedy? A declaratory judgment? He can't set the np aside and he definitely can't get money. Ori inal Messa e l e :54:03 2011 Subject: RE: Setting aside the non-pros and prosecuting him as though the Non-pros had never been signed. 111111M Subject: Re: Suggest what thing? Sent: Mon Sep 26 15:48:05 2011 Subject: RE: EFTA00205761 No. He already served his sentence in state court and performed all his other obligations under the Non-Pros (including paying damages to 30-some girls). I argued it would be a Due Process violation to even suggest such a thing. ----Ori inal Messa e ' Have we conceded that a showing that we violated the CVRA would justify reo
Summary
Subject: RE: Re: Date: Mon, 26 Sep 2011 20:02:17 +0000 Importance: Normal Nobody knows. At the very first hearing -- 3 years ago — the judge said the most he could do is order us outside to "confer." Sent: Monday, September 26, 2011 3:56 PM Subject: Re: What if the court disagrees and says we violated cvra - what's the remedy? A declaratory judgment? He can't set the np aside and he definitely can't get money. Ori inal Messa e l e :54:03 2011 Subject: RE: Setting aside the non-pros and prosecuting him as though the Non-pros had never been signed. 111111M Subject: Re: Suggest what thing? Sent: Mon Sep 26 15:48:05 2011 Subject: RE: EFTA00205761 No. He already served his sentence in state court and performed all his other obligations under the Non-Pros (including paying damages to 30-some girls). I argued it would be a Due Process violation to even suggest such a thing. ----Ori inal Messa e ' Have we conceded that a showing that we violated the CVRA would justify reo
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Case 9:08-cv-80119-KAM
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
Case 9:08-cv-80119-KAM
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
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
Case 9:08-cv-80119-KAM Du..ument 511 Entered on FLSD Docku, J3/29/2010 Page 1 of 11
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