Epstein Secrets

)(4)." United States v. Okun, 2009 WL 790042 at *2 (E.D.Va. 2009). Still another decision at odds with the Government's position is United States v. Rubin, 2008 WL 2358591 (E.D.N.Y. 2008). This decision is instructive because it not only explains that victims have rights before the formal filing of ch

411 (E.D.N.Y. 2008)— specifically contradicts the Government's position that victims are not entitled to obtain information from the Government. In Rubin, crime victims argued that "the government has not provided information with which to pursue restitution in this ease." Id. at 425. The district co

EFING SCHEDULE AND HEARING ON THE APPROPRIATE REMEDIES. For all the reasons just explained, the Court should find that the Government has violated Jane Doe NI and Janc Doe #2's rights under the CVRA. At the tail end of its brief, however, the Government briefly raises a flurry of desperate arguments to avo

has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WL 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under 29 EFTA00208402 Case 9:08-cv-80736-KAM Document 48 Entered

at 234-37; Tr. July 11, 2008, 18-19, 22-23, 28- 29? 21. In October 2007, shortly after the initial plea agreement was signed, FBI agents contacted Jane Doe NI. On October 26, 2007, Special Agents and met in person with Jane Doe #1. The Special Agents explained that Epstein would 3 On about August 14, 200

n Dean has been cited in one very recent District Court decision, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WI. 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under the CVRA. After citing Dean, the District Court agreed that

t the Government to produce all evidence that it possesses supporting these facts, for reasons the victims explain in their contemporaneously-filed Jane Doe NI and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence. 3 EFTA00210792 Case 9:08-cv-80736-KAM

has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WL 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under 29 EFTA00079021 Case 9:08-cv-80736-KAM Document 48 Entered

that the plea agreement made it impossible to prosecute Epstein federally for his crimes against them, they would have objected to this resolution. Jane Doe NI and Jane Doe #2 thus detrimentally relied on the inaccurate representations of the U.S. Attorney's Office that their cases were still under investi

has been cited favorably in two recent District Court decisions, which provides further support for Petitioner's position here. In United States v. Rubin, 2008 WL 2358591 (BD.N.Y. 2008), the victims argued for extremely broad rights under 29 EFTA00229945 , , , , , , , • Case 9:08-cv-80736-KAM D

ary 2008 and May 2008. At no time before reaching the non-prosecution agreement did the Justice Department notify any victims, including for example Jane Doe NI, about the non-prosecution agreement. The victims were therefore prevented from exercising their CVRA right to confer with prosecutors about the ca