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would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006); (wh
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
would violate the laws of this state"); Ex parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006); (wh
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
a et Sconce -i ISO SeclIIINS Commoners PROPERTY RICH T9 3 120 Cannabis 71130 Pawn 3 $40 Tin:knurl
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
would violate the laws of this state"); Re parte Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006); (wh
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 Marc Rich and Jane Doe NI

Jeffrey Epstein
PERSON
Lesley Groff
PERSONLarry Visoski
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Bradley Edwards
PERSONMaria Farmer
PERSON
Sarah Kellen
PERSON
Virginia Giuffre
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSON
Madison
LOCATIONCourtney Wild
PERSON
Alexander Acosta
PERSON
David Rodgers
PERSON
Jean-Luc Brunel
PERSON