EFTA00027776.pdf

"Jane Doe 1 and 2 now offer their recommendations to the Court as to how to proceed to resolve their petition."

"Jane Doe 1 and 2 now offer their recommendations to the Court as to how to proceed to resolve their petition."

"the Government, now represented by the U.S. Attorney's Office for the Northern District of Georgia."

"The Government, then represented by the U.S. Attorney's Office for the Southern District of Florida, 'vehemently' opposed joinder."

"during an April 29, 2019, conference call between attorneys from the U.S. Attorney's Office for the Northern District of Georgia and counsel for Jane "

"the Government has a statutory obligation to see that Jane Doe 1 and 2 'are . . . accorded' their CVRA rights"

"The Government, then represented by the U.S. Attorney's Office for the Southern District of Florida, 'vehemently' opposed joinder."

"Jane Doe 1 and 2 provided ... on February 25, 2019 (four days after this Court's ruling) a follow up letter outlining a way to resolve the case."

"counsel for Jane Does 1 and 2"

"Jane Doe 1 (and then Jane Doe 2) filed this action in July 2008"

"the Court's binding ruling that the Government has violated its CVRA obligations"

"breakfast meeting that appears to have taken place on around October 12, 2007, between U.S. Attorney Acosta and Epstein attorney Jay Lefkowitz"

"Epstein attorney Jay Lefkowitz"

"We represent several victims of sex abuse and trafficking crimes committed by Jeffrey Epstein, including Jane Doe 1"

"several victims of sex abuse and trafficking crimes committed by Jeffrey Epstein, including Jane Doe 1"

"Letter from Paul G. Cassell to Ms. Arian Fajardo Orshan dated February 25, 2019 re: Protecting the Rights of Jeffrey Epstein's Victims"

"victims of federal sex abuse and sex trafficking crimes committed by Jeffrey Epstein, including Jane Doe 1"

"Counsel for Jane Doe 1, Jane Doe 2, Jane Doe 3, and Jane Doe 4"

"Counsel for Jane Doe 1, Jane Doe 2, Jane Doe 3, and Jane Doe 4"

"Ms. Arian Fajardo Orshan U.S. Attorney for the Southern District of Florida"

"Judge Marra has directed that we confer to determine whether we can jointly fashion a remedy"

"Intervenor Jeffrey Epstein is permitted to file, if he so chooses, any response"

"petitioners Jane Doe 1 and Jane Doe 2's right to conferral was violated"

"immediately rescind the provisions in the non-prosecution agreement barring prosecution of Epstein and his co-conspirators"

"The Government shall bear the costs associated with the settlement conference"

"Jane Doe 1 and 2 filed this action in 2008, alleging a violation of their rights."

"Jane Doe 1 and 2 filed this action in 2008, alleging a violation of their rights."

"the Government entered into a[n] NPA with Epstein without conferring with Petitioners during its negotiation and signing."

"the Government (and Epstein) purposely concealed the consummation and execution of a secret non-prosecution agreement (NPA)."

"the Government (and Epstein) purposely concealed the consummation and execution of a secret non-prosecution agreement (NPA)."

"the Southern District of Florida has been recused from the CVRA litigation."

"On March 6, 2019, the U.S. Attorney's Office for the Northern District of Georgia contacted Jane Doe I and 2's counsel"

"holding that Jane Doe 1 and 2's right to conferral under the CVRA was violated."

"The Court has previously granted Epstein's motion to intervene on remedy issues that might affect him."

"Epstein also intervened and succeeded in delaying the case for a year while he took a meritless interlocutory appeal to the Eleventh Circuit. See Jane"

"Jane Doe 1 and 2 provided the Government with a specific list of possible remedies that they were seeking in 2011."

"In 2016 Jane Doe 1 and 2 had joined with the Government in requesting a mediation, which this Court ordered. DE 374. However, that mediation effort wa"

"fighting the Government to vindicate their rights as Epstein's victims"

"fighting the Government to vindicate their rights as Epstein's victims"

"determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all other similarly situated victims under the CVRA"

"determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all other similarly situated victims under the CVRA"

"Epstein has forfeited any right to seek specific performance of the non-prosecution agreement"

"discovery in the form of document requests and requests for admissions from the U.S. Attorney's Office"

"Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 ... at his mansion in Palm Beach, Florida"

"Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 ... at his mansion in Palm Beach, Florida"

"your Office entered into a non-prosecution agreement with Epstein, in which your Office agreed not to prosecute him for federal sex abuse crimes commi"

"facts that were all recently found by U.S. District Judge Kenneth Marra in his detailed opinion and order granting our clients summary judgment"

"finding that your Office had violated the CVRA. Opinion and Order, Jane Does v. United States, No. 9:08-cv-80736"

"Particularly problematic was the Government's decision to conceal the existence of the NPA and mislead the victims to believe that federal prosecution"

"at his mansion in Palm Beach, Florida"