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nd 2007, defendant Jeffrey Epstein (a billionaire with significant political connections) sexually abused more than 30 minor girls at his mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane 2 The Court should accept all these facts as true for reasons
ce with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States v. McCorkle, 321 F.3d 1292 (11'" Cir. 2003). Each of these four factors is easily met here. First, the Government made statements to the victims that induced r
nd 2007, defendant Jeffrey Epstein (a billionaire with significant political connections) sexually abused more than 30 minor girls at his mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane 2 The Court should accept all these facts as true for reasons
ence with regard to the acts, conduct, or acquiescence; (3) detrimental reliance; and (4) affirmative misconduct by the Government. United States. McCorkle, 321 F.3d 1292 (11'" Cir. 2003). Each of these four factors is easily met here. First, the Government made statements to the victims that induced r
4 Entered on FLSD DOet 03/21/ U.S. Department of Justice United States Attorney Southern District of Ronda 500 South Australian Are., Suite 000 West Palen Beach. FL 33401 (560 870-871 Facsimile: (561)820-8777 August 11, 2006 DELIVERY BY HAND Miss Tea Re: Crime Victims' and Witnesses' Rights Dear Miss
ement barring federal prosecution of their oases because of a deliberate decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorkle, 321 F.3d at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights Act does not apply to this case. IL THE COU
4 Entered on FLSD DOet 03/21/ U.S. Department of Justice United States Attorney Southern District of Ronda 500 South Australian Are., Suite 000 West Palen Beach. FL 33401 (560 870-871 Facsimile: (561)820-8777 August 11, 2006 DELIVERY BY HAND Miss TOMS Re: Crime Victims' and Witnesses' Rights Dear Miss
ement barring federal prosecution of their oases because of a deliberate decisions by the U.S. Attorney's Office, not mere "negligence or inaction." McCorkle, 321 F.3d at 1297. Accordingly, the Government is stopped from arguing that the Crime Victims' Rights Act does not apply to this case. IL THE COU
Entities connected to both West Palm Beach and McCorkle

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Palm Beach
LOCATION
United States
LOCATION
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATIONLeon Black
PERSON
Alan Dershowitz
PERSON
Palm Beach County
LOCATION
Alexander Acosta
PERSONthe Southern District
LOCATION
West Palm
LOCATION
Palm Beach Police Department
ORGANIZATION
Donald Trump
PERSON
Scarlett Johansson
PERSON