7
Shared Docs
3
Same-Page
12 / 7
Mentions
736-KAM Document 416 Entered on FLSD Docket 08/11/2017 Page 23 of 65 So far as appears in the available public materials, Senator Kyl's concern that the Justice Department's policy of conferring with victims about plea agreements before charges were filed would be a "dead letter" went unaddressed. Even today, the Justice
cted with the Justice Department's other statements on combatting sex abuse and trafficking. Attorney General Eric H. Holder Jr. Delivers Remarks at Justice Department Event Marking National Slavery and Human Trafficking Prevention Month (Jan. 29, 2015) http:/Avww.justice.gov/opa/speech/attomey-general-eric-h- holder-jr-
are irrelevant, and we really hope he does not prove the point that a man can commit heinous crimes against children and buy his way out of it. If the Department of Justice's recent commitment to the protection of our children from child molesters is to be more than rhetoric, then this is the time and the case where the
was relieved of its CVRA obligations. Of course, an agency's own "'interpretation' of the statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Whatever the Attorney General may have said in his Guideline, the ultimate issue in this case remains what the
the crimes against the victims; (3) discovery of records explicating why the U.S. Attorney's Office decided to grant Epstein federal immunity; (4) the Department of Justice's designation of a representative to explain the Office's decision to resolve the Epstein case without any federal prosecution; (5) mandatory CVRA t
ice Department's Office of Legal Counsel ("OLCi. Maj. Op. at 1213-14 n.20. The Justice Department's 2010 OLC opinion, like the change of position by the Justice Department's local U.S. Attorney's Office, came only after Epstein's victims filed this lawsuit. See Mohasco Corp. v. Silver, 447 U.S. 807, 825, 100 S. Ct. 2486,
on, like the change of position by the Justice Department's local U.S. Attorney's Office, came only after Epstein's victims filed this lawsuit. See Mohasco Corp. v. Silver, 447 U.S. 807, 825, 100 S. Ct. 2486, 2497, 65 L.Ed.2d 532 (1980) (holding that an agency's "interpretation' of a statute cannot supersede
]he right to be treated with fairness," and "the right to petition the Court for relief' if Wild believed her CVRA rights were being violated; (2) "the U.S. Department of Justice and other federal investigative agencies, including the [FBI], must use their best efforts to make sure that these rights are protected"; and (3)
eading Law: The Interpretation of Legal Texts 170 (2012) ("A word or phrase is presumed to bear the same meaning throughout a text ...."); cf. also Mohasco Corp. v. Silver. 447 U.S. 807, 826, 100 S.Ct. 2486.65 L.Ed.2d 532 (1980) (rejecting interpretation that would "giv[e] the word 'filed' two different mean
v. United States, 817 F.Supp.2d 1337, 1341 (S.D. Fla. 2011). Epstein also fails to fully describe what the Justice Department regulations required the Justice Department to do during the investigative stage of a case. The 2005 Attorney General Guidelines for Victim and Witness Assistance (hereinafter "2005 A.G. Victi
Page: EFTA00021457 →obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Given that the USAO-SDFL had told the victims that the CVRA applied, it was obligated to confer with them and
Page: EFTA00021459 →1(b)(1) (emphasis added). This Court also previously held that "[w]hile Epstein was within his rights to attempt to persuade higher authorities with the Department of Justice to overrule the prosecutorial decisions of the U.S. Attorney's Office in the Southern District of Florida, the CVRA was designed to give victims the
Page: EFTA00021469 →v. United States, 817 F.Supp.2d 1337, 1341 (S.D. Fla. 2011). Epstein also fails to fully describe what the Justice Department regulations required the Justice Department to do during the investigative stage of a case. The 2005 Attorney General Guidelines for Victim and Witness Assistance (hereinafter "2005 A.G. Victi
Page: EFTA00022561 →obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Given that the USAO-SDFL had told the victims that the CVRA applied, it was obligated to confer with them and
Page: EFTA00022563 →1(b)(1) (emphasis added). This Court also previously held that "[w]hile Epstein was within his rights to attempt to persuade higher authorities with the Department of Justice to overrule the prosecutorial decisions of the U.S. Attorney's Office in the Southern District of Florida, the CVRA was designed to give victims the
Page: EFTA00022573 →he 'right not to be excluded from any such public court proceeding....' 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that 'employees of the Department ofJustice ... engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime 14 EFTA00010520 --- PAGE BREAK
Page: EFTA00010521 →obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Next, the Court rejects the Government's contention that Jane Doe 2 is not protected by 31 EFTA00010537 ---
Page: EFTA00010538 →he 'right not to be excluded from any such public court proceeding....' 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that 'employees of the Department ofJustice ... engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime 14 EFTA00027679 --- PAGE BREAK
Page: EFTA00027680 →obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). Next, the Court rejects the Government's contention that Jane Doe 2 is not protected by 31 EFTA00027696 ---
Page: EFTA00027697 →Entities connected to both Department of Justice and Mohasco Corp.

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSONFBI
ORGANIZATIONLeon Black
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Scarlett Johansson
PERSON
Michael Cohen
PERSON
Jay Lefkowitz
PERSON
Southern District of New York
ORGANIZATION
Michael Jackson
PERSON
Marc Rich
PERSON
Prince Charles
PERSON
A. Marie Villafana
PERSON
Paul Cassell
PERSON