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ations to the victims — and having induced reliance by the victims —the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in
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
8 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be expansive. For Interestingly, in In re Stewart, the Eleventh Circuit stated that the CVRA "does not limit the class of victims to those whose identity constitutes an element of the offense or who happen to be identif
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
ations to the victims — and having induced reliance by the victims —the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in
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
tations to the victims — and having induced reliance by the victims—the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in
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
Entities connected to both the Eleventh Circuit and Jane Doe NI

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Scarlett Johansson
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONJack Goldberger
PERSONLeon Black
PERSON
Paul Cassell
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONMaria Farmer
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON