EFTA00010507.pdf

"From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1"

"From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2"

"Jane Doe 1 provided information about her abuse and Jane Doe 2's abuse to the FBI on August 7, 2007."

"Assistant United States Attorney ("AUSA" "line prosecutor" testified that both Jane Doe 1 and Jane Doe 2 received letters"

"at his mansion in Palm Beach, Florida"

"JANE DOE 1 AND JANE DOE 2, Petitioners"

"UNITED STATES, Respondent."

"the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein and his personal assistants used the facilities of i"

"On September 24, 2007, Epstein and the Office formally reached an agreement whereby the United States would defer federal prosecution in favor of pros"

"On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz"

"the line prosecutor wrote to defense counsel Jay Lefkowitz: Please send [a document] to my home e-mail address"

"I believe that Mr. Epstein's airplane was in Miami on the day of the [co-conspirator] telephone call."

"I have compiled a list of 34 confirmed minors. ... confirming the girls' status as victims"

"Palm Beach County State Attorney Krischer wrote the line prosecutor about the proposed agreement and added: Glad we could get this worked out for reas"

"I have forwarded your message only to [United States Attorney] Alex [Acosta]"

"the line prosecutor wrote to Epstein's counsel indicating that the Office did not like the factual basis"

"the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein"

"Epstein's counsel... Lefkowitz responded by stating"

"On about October 26 or 27, 2007, Special Agent and Jason Richards met in person with Jane Doe 1."

"Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms"

"On October 24, 2007, AUSA Jeff sent a letter to Jay Lefkowitz, proposing an addendum"

"the line prosecutor sent an email to state prosecutors Lanna Belohlavek and Krischer"

"recruit underage females to travel to his home in Palm Beach"

"Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms."

"U.S. Attorney Acosta sent a letter to one of Epstein's defense attorneys, Kenneth Stan"

"defense attorney Lilly Ann Sanchez sent a letter to AUSA requesting that the Office hold off on sending any victim notification letters."

"Lefkowitz sent a letter to U.S. Attorney Acosta"

"AUSA from the U.S. Attorney's Office"

"She provided additional details of Epstein's sexual abuse of her."

"On November 29, 2007, Lefkowitz sent a letter to U.S. Attorney Acosta objecting to the proposed victim notification letter"

"On about November 30, 2007, U.S. Attorney Acosta sent a letter to one of Epstein's defense attorneys, Kenneth Stan"

"On December 5, 2007, Stan sent a letter to U.S. Attorney Acosta... asking about issuance of victim notification letters"

"On January 31, 2008, Jane Doe 1 met with FBI Agents and an AUSA from the U.S. Attorney's Office."

"Epstein had signed the NPA in September 2007."

"he represented Jane Doe 1 and, later, Jane Doe 2."

"he represented Jane Doe 1 and, later, Jane Doe 2."

"The line prosecutor did not inform REDACTED-001 about the NPA."

"On June 30, 2008, Jeffrey Epstein ... entered a plea of guilty to violations of Florida statutes forbidding the solicitation of minors to engage in pr"

"the line prosecutor sent an email to Lefkowitz stating that the Deputy Attorney General had completed his review of the Epstein matter"

"Jane Doe 5 ... received a letter from the FBI advising her that this case is currently under investigation."

"The notification letter to Jane Doe 5 was sent by the Office, and the line prosecutor corresponded on behalf of the Office."

"the Deputy Attorney General had completed his review of the Epstein matter and determined that federal prosecution of Mr. Epstein's case is appropriat"

"the line prosecutor corresponded with Epstein's counsel seeking his signed agreement concerning a notification letter"

"On July 10, 2008, Epstein's counsel continued to protest victim notification as evidenced by an email to the line prosecutor"

"On August 18, 2008, Lefkowitz wrote the line prosecutor that Epstein objected to disclosure of the terms of the NPA"

"On August 21, 2008, the Government sent a letter to Epstein's counsel stating that, [c]opies of the victim notifications will continue to be provided "

"Jane Doe 1 and Jane Doe 2 filed actions in Palm Beach County, seeking money damages from Epstein from sexually abusing them."

"On September 16, 2008, attorney Jeffrey Herman... wrote to the line prosecutor to object to the restitution procedures established in the NPA"

"On September 17, 2008, the line prosecutor sent an email to State Attorney Krischer, explaining that the NPA contained a confidentiality provision"

"In moving for summary judgment, the Petitioners make the following arguments in support of their contention that the Government violated their CVRA ri"