Epstein Secrets

• Government's Response to Petitioners' Submission on Proposed Remedies The United States of America, by Byung J. Pak, United States Attorney for the Northern District of Georgia, and Jill E. Steinberg and Nathan P. Kitchens, Special Attorneys for the Southern District of Florida, files this response to Petitioners' proposed

ails. The traditional rule of grand jury secrecy may be set aside under certain circumstances prescribed by Federal Rule of Criminal Procedure 6(e). The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." United States v. Aisenberg, 3

the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00021446 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 6 of 70 THIS CASE MUST BE DECIDED

omehow the "forthwith" deadline in this case had been missed, that fact would not allow it to refuse to enforce Jane Doe 1 and 2's CVRA rights now. The U.S. Supreme Court has explored a similar question of a missed deadline in connection with restitution for crime victims. Dolan v. United States, 560 U.S. 605 (2010),

the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00022550 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 6 of 70 THIS CASE MUST BE DECIDED

omehow the "forthwith" deadline in this case had been missed, that fact would not allow it to refuse to enforce Jane Doe 1 and 2's CVRA rights now. The U.S. Supreme Court has explored a similar question of a missed deadline in connection with restitution for crime victims. Dolan v. United States, 560 U.S. 605 (2010),