Epstein Secrets

orney's Office for violating Jane Doe #1 and Jane Doe #2's rights; • A monetary sanction imposed against the U.S. Attorney's Office, to be paid to Jane Doe #1 and Jane Doe #2 directly or to any other appropriate person or entity;; • An order establishing the precise rule regarding the timing of the obli

es not cite the applicable civil rule is that it has yet to state clearly whether it is willing to abide by the civil rules in this case. See, e.g., Gov't Resp. Mot. Order Not Withhold Evid., DE #59 at 6-7 (refusing to take a position on whether civil rules apply or not). Indeed, the Government has yet to

orney's Office for violating Jane Doe #1 and Jane Doe #2's rights; • A monetary sanction imposed against the U.S. Attorney's Office, to be paid to Jane Doe #1 and Jane Doe #2 directly or to any other appropriate person or entity;; • An order establishing the precise rule regarding the timing of the obli

es not cite the applicable civil rule is that it has yet to state clearly whether it is willing to abide by the civil rules in this case. See, e.g., Gov't Resp. Mot. Order Not Withhold Evid., DE #59 at 6-7 (refusing to take a position on whether civil rules apply or not). Indeed, the Government has yet to

pstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane Doe #1 and Jane Doe #2's Response to Motion to Intervene (DE 78) at 4-6. Perhaps recognizing the strength of the victims' response, the defense attorne

2). Epstein's lawyers, To be sure, as the Government points out, effective defense counsel should always explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130 S.C.t 1473, 1485 (2010)). But this is a far cry from proving there is a "right" to plea bargaining or that p

FLSD Docket 05/02/2011 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO THEIR MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE

arding the correspondence, consistent with an earlier order of the magistrate judge. In response, the Government "takes no position" on the motion. Gov't Resp. at 1. Accordingly, this part of the victims' motion should be granted. II. NONE OF THE MATERIALS IN THE CORRESPONDENCE ARE BARRED FROM DISCLOSUR

ecute the specific offenses that were committed against these victims. The Government violated the rights that the CVRA extended to Jane Doe #1 and Jane Doe #2. The Government did not afford the victims their right to confer about the non- prosecution agreement (NPA) it negotiated with Jeffrey Epstein — a

gainst Jeffrey Epstein in the U.S. District Court, Southern District of Florida, . . . [the victims] cannot invoke any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply irreconcilable with § 3771(c)(1) of the CVRA. If an indictment is a prerequisite to CVRA rights, then depar

FLSD Docket 05:02/2011 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO

ernment also cites several cases in which district courts have declined to turn over to crime victims their own confidential pre-sentencing reports. Gov't Resp. at 3-4. These cases about judicial obligations say nothing about prosecutorial obligations under the CVRA "best efforts" provision. It is unsurpri

FLSD Docket 05:02/2011 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO THEIR MOTION TO HAVE THEIR FACTS ACCEPTED BECAUSE OF THE GOV

ed by evidence in the record." The Government has briefly recounted a few facts in opposition to a small sliver of the victims' proposed facts. See Gov't Resp. to Victims' Motion to Have Facts Accepted at 11-13. But none of these facts are supported by any evidence at all. The Government should have at le

Gov't Resp. to 2d RFA 14(a) (The Government "denies that, during the period from September 24, 2007,through June 2008, the USAO-SDFL did not inform Jane Doe 1 that the non-prosecution agreement would block prosecution of the federal offenses committed against her by Jeffrey Epstein and his potential co- co

nt on this point, the Government has contested those requests — even arguing that its FBI agents properly and fully informed the victims. See, e.g., Gov't Resp. to 2d RFA 14(a) (The Government "denies that, during the period from September 24, 2007,through June 2008, the USAO-SDFL did not inform Jane Doe 1

o intervene at this time because the issue of whether the Crime Victims' Right Act even applies in this case is a matter between the government and Jane Doe 1 and Jane Doe 2 . . . ." Mot. at 5. By conceding this point on behalf of Jeffrey Epstein, the defense attorneys have conceded that Epstein knows th

against Jeffrey Epstein in the U.S. District Court, Southern District of Florida, . . [the victims] cannot invoke any protections under the CVRA." Gov't Resp. at 8. This sweeping position is simply irreconcilable with § 3771(c)(I) of the CVRA. If an indictment is a prerequisite to CVRA rights, then depar

DE 361 at 8, 1 1. Because Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2, and other similarly situated victims, they committed violations of not only Florida law see, e.g., Ha. Stat. §§ 794.05, 796.04, 796.045, 39.201 & 7

ims' S.J. Mot."), DE 361 at 7-47 (listing 157 proposed undisputed facts). The Government has responded by contesting some facts, but not others. See Gov't Resp. to 2 EFTA00597319 Case 9:08-cv-80736-KAM Document 417 Entered on FLSD Docket 08/11/2017 Page 3 of 33 Petitioners' Statement of Undisputed Mater