Epstein Secrets

RA rights to confer and fairness in cases involving white- collar and other wealthy defendants who commonly engage in pro-charge plea negotiations. Jeffrey Epstein's case illustrates my point. The U.S. Attorney's Office assigned specific attorneys, with AUSA Villafana being the lead prosecutor and primary attorn

rey Epstein. In her petition, Ms. Wild alleges that when federal prosecutors secretly negotiated and entered into a non- prosecution agreement with Epstein in 2007, they violated her rights under the CVRA—in particular, her rights to confer with the government's lawyers and to be treated fairly by the

ized by notorious sex trafficker and child abuser Jeffrey Epstein. In her petition, Ms. Wild alleges that

t resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identif

tions. Federal courts have had broad authority to fashion equitable remedies after petitioners have proven a violation of statutory provisions. It Hardison v. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004); Nichols v. Ho per 173 F.3d 820, 824 (11th Cir. 1999); C e Ala. Hosp Ass'n v Beasley, 702 £2d 955, 962 (1 I

the victims explained in their motion for summary judgment (DE 361), the undisputed facts of this case show that for nine months, the Government and Epstein conspired to conceal a non-prosecution agreement (NPA) from Epstein's victims in order to prevent them from voicing any objection to the agreement.

ed Jane Doe 1 and Jane Doe 2 (and several other victims) in civil suits against Jeffrey Epstein for injuries my clients suffered as a consequence of Jeffrey Epstein's sexual abuse of them. 2. I have previously filed an affidavit in this matter (see DE 225-1). This affidavit repeats some of the information contai

Undisputed Fact 1 ("Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls,

she, herself] procured additional young women for Mr. Epstein and [was] paid commissions or referral fees for

scheme for enforcement of congressionally-created rights, the courts must give "appropriate judicial deference toward the will of Congress . . . ." Hardison v. Cohen, 375 F.3d 1262, 1264 (11th Cir. 2004) (internal quotation omitted). Congress is "in a better position to decide whether or not the public interest

t the victims' pleadings are facially deficient, the Court must assume the truth of the victims' allegations — specifically that the Government and Epstein deliberately conspired to enter into a secret non- prosecution agreement in violation of the victims' rights under the Crime Victims' Rights Act (CV

:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 6 of 25 historically had broad authority to fashion equitable remedies . . . ." Hardison v. Cohen, 375 F.3d 1262, 1266 (11th Cir. 2004). The Eleventh Circuit has expressly required district courts to fashion appropriate equitable remedies when p