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Petition for Enforcement of Crime Victim's Rights Act, 18 USC Section 3771 (DE I) ("Victim's Petition") in Case No.: 9:08-cv-80736-Marra/Johnson in the Southern District of Florida, filed on July 7, 2008. Based upon the facts set forth in the Court filings that are unsealed, I recommend that the Federal Bureau of In
leges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe NI and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision
Petition for Enforcement of Crime Victim's Rights Act, 18 USC Section 3771 (DE I) ("Victim's Petition") in Case No.: 9:08-cv-80736-Marra/Johnson in the Southern District of Florida, filed on July 7, 2008. Based upon the facts set forth in the Court filings that are unsealed, I recommend that the Federal Bureau of In
leges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe NI and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision
A ripened at the moment of actual victimization, or at least at the point when they first contacted the government. Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court re
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 alleged that, "[u]pon information and believe, [Jeffrey Epstein] is engaged in plea negotiations with the Office of the United States Attorney for the Southern District of Florida concerning federal crimes which he is alleged to have committed against minor children, including [Jane Doe No. 1]." DE 1 at 1-2. Jane D
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
against Epstein, they asserted their rights "in the district court in the district in which the crime occurred" — i.e., the U.S. District Court for the Southern District of Florida. The Government does find room in its pleading to analyze this provision, calling it a mere "venue provision." Gov't Resp. at 13. But ev
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
A ripened at the moment of actual victimization, or at least at the point when they first contacted the government. Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court re
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
A ripened at the moment of actual victimization, or at least at the point when they first contacted the government. Movants rely on a decision from the Southern District of Texas for the notion that CVRA rights apply prior to any prosecution. In United States v. BP Products North America, Inc., the district court re
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
orida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein
tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres
orida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein
tter that contained the language from "Part 3" of the Agreement. Based upon that communication, your Affiant sent the victim notification letter to Jane Doe NI and attached it to your Affiant's July 9,2008 Declaration. 6. Although copies of all of the victim notification letters, including the one addres
Entities connected to both the Southern District and Jane Doe NI

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Alexander Acosta
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
the United States District Court
ORGANIZATION
Alan Dershowitz
PERSONLeon Black
PERSONJack Goldberger
PERSON
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
Jay Lefkowitz
PERSON