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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
earlier pleadings filed in this action, the Government has tried to narrowly construe the CVRA so that it applies only to a "court proceeding." See Gov't Response to Victim's Emergency Petition (doc. #13) at 1-2. The Government's position contravenes the plain language of the CVRA. The CVRA guarantees to Jan
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
e, the Government's lead argument in its response is that there was no "court proceeding" in this case that triggered Petitioner's right to confer. Gov't Response at 1-2. The Government's position flouts the plain language of the CVRA. The CVRA guarantees to Petitioner the right to confer with prosecutors "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
earlier pleadings filed in this action, the Government has tried to narrowly construe the CVRA so that it applies only to a "court proceeding." See Gov't Response to Victim's Emergency Petition (doc. #13) at 1-2. The Government's position contravenes the plain language of the CVRA. The CVRA guarantees to Jan
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
earlier pleadings filed in this action, the Government has tried to narrowly construe the CVRA so that it applies only to a "court proceeding." See Gov't Response to Victim's Emergency Petition (doe. #13) at 1-2. The Government's position contravenes the plain language of the CVRA. The CVRA guarantees to Jan
Entities connected to both Jane Doe NI and Gov't Response
the Southern District
LOCATION
Scarlett Johansson
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Jeffrey Epstein
PERSON
United States
LOCATIONJack Goldberger
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
Bradley Cooper
PERSONRubin
PERSON
Lilly Ann Sanchez
PERSON
Palm Beach County
LOCATIONCriminal No
ORGANIZATION
Marc Rich
PERSONGarcia
PERSON
Jay Lefkowitz
PERSONFBI
ORGANIZATIONWalker
PERSON