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e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4 EFTA00207883 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein w
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
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min
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 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00208406 Case 9:08-cv-80736-KAM Document 48 Entered on F
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min
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 (11a ' Cir. 2003). Each of these four factors is easily met here. 33 EFTA00210822 Case 9:08-cv-80736-KAM Document 48 Entered on F
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4 EFTA00235754 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein w
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
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min
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 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00079025 Case 9:08-cv-80736-KAM Document 48 Entered on FL
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min
nce 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 (I l" Cir. 2003). Each of these four factors is easily met here. 33 EFTA00185041 Case 90B-cava7236-11CMil Banuarand 3162- etas* R
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min
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 (11th Cir. 2003). Each of these four factors is easily met here. 33 EFTA00177041 Case 9:08-cv-80736-KAM Document 48 Entered on F
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The F131 soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were mi
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
e. See generally U.S. Attorney's Correspondence, Exhibit "A" to this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates page number stamp). 4. The FBI soon determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were min
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 Bates and McCorkle

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
United States
LOCATIONMaria Farmer
PERSONJane Doe
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSONLeon Black
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Jay Lefkowitz
PERSON
Virginia Giuffre
PERSON
S.J. Quinney College of Law
ORGANIZATION
David Rodgers
PERSON