Epstein Secrets

isite to rescission is placing the other party in status quo"); Renfrowl First Mortg. America, Inc., 2011 WL 2416247, *3 (S.D. Fla. June 13, 2011) (Marra, J.) ("restoring the parties to the status quo ante is an element of a rescission claim"); see also, e.g., Blinco, 400 F.3d at 1312; AWA-BC, 25 So.

tims of a crime veto power over any prosecutorial decision, strategy or tactic regarding bail, release, plea, sentencing or parole.") (citing In re W.R. Huff 409 F.3d 555, 564 (2d Cir. 2005) ("Nothing in the CVRA requires the Government to seek approval from crime victims before negotiating or entering in

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioner

tlement, factors which Congress has required the court to consider. See 18 U.S.C. § 3771(d)(2). W.R. me, 409 F.3d at 564. In this instance, as in W.R. Huff, there was an un-convicted defendant, Epstein. Unlike in W.R. me, here Epstein was the only defendant. Nonetheless, the AUSA who investigated Epst

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioner

restitution measures against nonconvicted defendants." In re W.R. Hu fir Asset Mgt. Co., LLC , 409 F.3d 555, 564 (2d Cir. 2005) (emphasis added). In W.R. Huff, petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the

TED STATES OF AMERICA, RESPONDENT. 08-80736-CIV-MARRA • Government's Response to Petitioners' Submiss

ovided in law," thus recognizing that there would be numerous situations when it would be impossible for a victim to receive restitution. See In re W.R. Huff, 409 F.3d 555, 563 (2d Or. 2005). The statute under which Petitioners urge this Court to award restitution does not make the government liable for

ite to rescission is placing the other party in status quo"); Renfrow v. First Mortg. America, Inc., 2011 WL 2416247, *3 (S.D. Fla. June 13, 2011) (Marra, J.) ("restoring the parties to the status quo ante is an element of a rescission claim"); see also, e.g., Banco, 400 F.3d at 1312; AVVA-BC, 25 So.

tims of a crime veto power over any prosecutorial decision, strategy or tactic regarding bail, release, plea, sentencing or parole.") (citing In re W.R. Huff, 409 F.3d 555, 564 (2d Cir. 2005) ("Nothing in the CVRA requires the Government to seek approval from crime victims before negotiating or entering i

ite to rescission is placing the other party in status quo"); Renfrow v. First Mortg. America, Inc., 2011 WL 2416247, *3 (S.D. Fla. June 13, 2011) (Marra, J.) ("restoring the parties to the status quo ante is an element of a rescission claim"); see also, e.g., Banco, 400 F.3d at 1312; AVVA-BC, 25 So.

tims of a crime veto power over any prosecutorial decision, strategy or tactic regarding bail, release, plea, sentencing or parole.") (citing In re W.R. Huff, 409 F.3d 555, 564 (2d Cir. 2005) ("Nothing in the CVRA requires the Government to seek approval from crime victims before negotiating or entering i

ite to rescission is placing the other party in status quo"); Renfrow v. First Mortg. America, Inc., 2011 WL 2416247, *3 (S.D. Fla. June 13, 2011) (Marra, J.) ("restoring the parties to the status quo ante is an element of a rescission claim"); see also, e.g., Blinco, 400 F.3d at 1312; AVVA-BC, 25 So.

tims of a crime veto power over any prosecutorial decision, strategy or tactic regarding bail, release, plea, sentencing or parole.") (citing In re W.R. Huff, 409 F.3d 555, 564 (2d Cir. 2005) ("Nothing in the CVRA requires the Government to seek approval from crime victims before negotiating or entering i

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 I. UNITED S

r restitution measures against nonconvicted defendants." hi re W.R. Huff Asset Mgt. Co., LLC, 409 F.3d 555, 564 (2d Cir. 2005) (emphasis added). In W.R. Huff petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the

Epstein's non-prosecution agreement 08-80736-CV-MARRA 000770 EFTA00230594 Case 9:08-cv-80736-KAM Do

ttlement, factors which Congress has required the court to consider. See 18 U.S.C. § 377l(dX2). W11. Huff 409 F.3d at 564. In this instance, as in W.R. Huff there was an un-convicted defendant, Epstein. Unlike in Wit. Huff here Epstein was the only defendant. Nonetheless, the AUSA who investigated Epste

ite to rescission is placing the other party in status quo"); Renfrow v. First Mortg. America, Inc., 2011 WL 2416247, *3 (S.D. Fla. June 13, 2011) (Marra, J.) ("restoring the parties to the status quo ante is an element of a rescission claim"); see also, e.g., Banco, 400 F.3d at 1312; AVVA-BC, 25 So.

tims of a crime veto power over any prosecutorial decision, strategy or tactic regarding bail, release, plea, sentencing or parole.") (citing In re W.R. Huff, 409 F.3d 555, 564 (2d Cir. 2005) ("Nothing in the CVRA requires the Government to seek approval from crime victims before negotiating or entering i