EFTA00021442.pdf

"JANE DOE #1 and JANE DOE #2 v. UNITED STATES"

"JANE DOE #1 and JANE DOE #2 v. UNITED STATES"

"The Government and Epstein reached a secret non-prosecution agreement (NPA) and then concealed that agreement until it was firmly in place"

"the NPA only covers the U.S. Attorney's Office for the Southern District of Florida"

"Bradley J. Edwards Edwards Pottinger LP"

"rescission of the NPA's immunity provisions, which have prevented victims from conferring with prosecutors in the USAO-SDFL about prosecuting Epstein"

"the NPA negotiated by Epstein with prosecutors in the Southern District of Florida only precludes his prosecution in the Southern District of Florida"

"former First Assistant U.S. Attorney Jeffrey Sloman"

"Intervenor Epstein is currently being prosecuted by federal prosecutors in the Southern District of New York"

"Rescission will vindicate Jane Doe 1 and 2's CVRA rights"

"Epstein filed a motion for limited intervention in this case"

"concluding that Jane Doe 1 was a victim of a federal crime committed by Epstein in the Southern District of Florida"

"the Government decided to conceal the existence of the NPA and mislead the victims to believe that federal prosecution was still a possibility"

"Intervenor Epstein also argues that his defense counsel acted in good faith"

"Jane Doe 1 v. United States, 749 F.3d 999"

"Epstein and his lawyers signed the NPA, which itself provided that '[t]he parties anticipate that this agreement will not be made part of any public r"

"documentary evidence in this case makes clear that at least one additional meeting was held off campus between the Government and Epstein"

"record evidence obviously demonstrates that Epstein and his lawyers signed the NPA"

"on about June 7, 2007, the USAO-SDFL sent official notices to Epstein victims informing them that they had rights under the CVRA."

"Jane Doe 1 and 2's Motion for Finding of Waiver of Work Product and Similar Protections and for Production of Documents, DE 414"

"USAO-SDFL was hiding from the victims that Epstein had already secured a signed agreement providing immunity from federal prosecution in Florida to hi"

"Jane Doe 1 and 2 alleged that on February I, 2007, the Epstein defense team sent a 24-page letter... falsely stated: Epstein did not know or believe a"

"Jane Doe 1 and 2 alleged that on February I, 2007, the Epstein defense team sent a 24-page letter to the Office"

"on July 6, 2007, Epstein's lawyers sent a 23-page letter to USAO-SDFL which falsely claimed that Mr. Epstein never targeted minors"

"Epstein is not entitled to take advantage of the non-prosecution provisions, at least with respect to crimes against Jane Doe 1 and 2"

"Jane Doe 1 and 2 reassert all of these thus-far uncontested factual claims and ask that the Court accept them as part of deciding the basis for crafti"

"Jane Doe 1 and 2 reassert all of these thus-far uncontested factual claims and ask that the Court accept them as part of deciding the basis for crafti"

"eliminate what is reportedly his main defense to recent sex trafficking charges in the Southern District of New York"

"Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019"

"the Government disclosed that it had, in fact, reached a secret agreement with Epstein months earlier."

"On July 7, 2008, when counsel for Jane Doe I began to learn that a secret, non-prosecution agreement might be in the works, they filed an emergency pe"

"On July 7, 2008, when counsel for Jane Doe I began to learn that a secret, non-prosecution agreement might be in the works... MR. EDWARDS: I was mista"

"Aware of the Government and Epstein's secret maneuvering in this case... the Government disclosed that it had, in fact, reached a secret agreement wit"

"this Court acted expeditiously and did take up and decide Jane Doe 1 petition (later joined by Jane Doe 2)"

"Jane Does v. United States, No. 13-12923... two days later, on July 9, 2008, the USAO-SDFL responded."

"the NPA directly provided that, if the USAO-SDFL was going to disclose the agreement, it was required to provide notice to Epstein before making that "

"the USAO-SDFL quickly notified Epstein of these proceedings, because disclosure of Epstein's then-secret NPA was involved."

"As soon as they had an inkling about a secret plea deal, Jane Doe 1 and 2 filed an emergency petition for review."

"As soon as they had an inkling about a secret plea deal, Jane Doe 1 and 2 filed an emergency petition for review."

"he did not move to intervene in the case until September 2, 2011 (DE 93), and even then he sought only limited intervention with regard to remedy."

"they were entitled to confer with the prosecutors before any immunity deal was struck with Epstein."

"Epstein would still continue to have the right to immunity from prosecution in the Southern District of Florida... (e.g., the NPA)"

"Epstein points to civil releases signed by Jane Doe 1 and 2 that resolved their civil cases against Epstein."

"Epstein points to civil releases signed by Jane Doe 1 and 2 that resolved their civil cases against Epstein."

"Epstein also suggests that, if a partial rescission remedy is awarded... Epstein Remedies Br. at 46."

"Jane Doe 1 and 2 propose, Epstein would still continue to have the right to immunity from prosecution in the Southern District of Florida for any vict"

"Jane Doe 1 and 2 propose, Epstein would still continue to have the right to immunity from prosecution in the Southern District of Florida"

"Epstein — a sex offender who worked with the USAO-SDFL to illegally conceal an NPA from minor sex abuse victims"

"Epstein — a sex offender who worked with the USAO-SDFL to illegally conceal an NPA from minor sex abuse victims"

"USAO-SDFL who, in the first instance, stymied the CVRA by illegally concealing their NPA."