EFTA00027776.pdf

1.98 MB
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Extraction Summary

16
People
9
Organizations
6
Locations
3
Events
3
Relationships
5
Quotes

Document Information

Type: Legal filing (petitioners' position on procedures, correspondence, proposed order)
File Size: 1.98 MB
Summary

This document is a legal filing by Petitioners Jane Doe 1 and 2 in May 2019, arguing for specific procedures to determine a remedy after the court ruled the Government violated the Crime Victims' Rights Act (CVRA) by secretly negotiating a Non-Prosecution Agreement (NPA) with Jeffrey Epstein. The petitioners argue the Government should immediately announce its proposed remedy, specifically the rescission of the NPA's immunity clauses, and request limited discovery including depositions of key figures like former U.S. Attorney Alexander Acosta and Epstein's attorney Jay Lefkowitz regarding a secret 2007 'breakfast meeting.' The filing includes correspondence between victims' counsel and the U.S. Attorney's Office, highlighting the Government's delay tactics and the recent recusal of the Southern District of Florida office.

People (16)

Name Role Context
Jane Doe 1 Petitioner/Victim
One of the two primary petitioners seeking remedy for CVRA violations.
Jane Doe 2 Petitioner/Victim
One of the two primary petitioners seeking remedy for CVRA violations.
Jane Doe 3 Victim
Victim seeking to join the case, previously blocked by Government objection.
Jane Doe 4 Victim
Victim seeking to join the case, previously blocked by Government objection.
Jeffrey Epstein Intervenor/Defendant
Perpetrator of sex crimes; intervenor in the civil case regarding the NPA remedy.
Bradley J. Edwards Attorney
Counsel for Jane Doe 1 and 2 (Edwards Pottinger LP).
Paul G. Cassell Attorney
Counsel for Jane Doe 1 and 2 (University of Utah).
Jack Scarola Attorney
Counsel for Jane Doe 1 and 2 (Searcy Denney Scarola Barnhart & Shipley).
Kenneth A. Marra Judge
U.S. District Judge presiding over the case.
Ariana Fajardo Orshan U.S. Attorney
U.S. Attorney for the Southern District of Florida, recipient of demand letters.
Alexander Acosta Former U.S. Attorney
Negotiated the original NPA; mentioned regarding a 'breakfast meeting' with Lefkowitz.
Jay Lefkowitz Attorney
Epstein's attorney who negotiated the NPA and attended the 'breakfast meeting'.
Roy Eric Black Attorney
Attorney for Jeffrey Epstein.
Jacqueline Perczek Attorney
Attorney for Jeffrey Epstein.
Sarah Schall Government Contact
Email recipient at USDOJ.
Barry Krischer Former State Attorney
Referred to as 'Palm Beach County State Attorney' (redacted/implied name context), involved in plea discussions.

Timeline (3 events)

2007-10-12
Breakfast meeting between U.S. Attorney Acosta and Epstein attorney Jay Lefkowitz where non-prosecution and victim notification restrictions were discussed.
Unknown (likely South Florida)
2019-02-21
Summary Judgment Order entered by Judge Marra finding the Government violated the CVRA.
SD Florida Court
Judge Marra Jane Doe 1 Jane Doe 2 United States
2019-05-10
Filing of Petitioners' Position on Procedures to Determine Remedy.
SD Florida Court
Jane Doe 1 Jane Doe 2 United States

Relationships (3)

Alexander Acosta Negotiation Jay Lefkowitz
Held a 'breakfast meeting' in 2007 to discuss NPA and victim notification restrictions.
Jane Doe 1 & 2 Adversarial/Legal United States Government
Petitioners vs Respondent in CVRA violation lawsuit.
Jeffrey Epstein Perpetrator/Victim Jane Doe 1 & 2
Epstein sexually abused more than 30 minor girls, including Petitioners.

Key Quotes (5)

"The Government should go first."
Source
EFTA00027776.pdf
Quote #1
"Epstein has 'forfeited' any right to seek specific performance of the non-prosecution agreement... he was a party to — and, indeed, the instigator of — the Government's CVRA violations."
Source
EFTA00027776.pdf
Quote #2
"Glad we could get this worked out for reasons I won't put in writing. After this is resolved I would love to buy you a cup at Starbucks and have a conversation."
Source
EFTA00027776.pdf
Quote #3
"The Government's hands were permanently tied if Epstein fulfilled his obligations under the NPA."
Source
EFTA00027776.pdf
Quote #4
"Particularly problematic was the Government's decision to conceal the existence of the NPA and mislead the victims to believe that federal prosecution was still a possibility."
Source
EFTA00027776.pdf
Quote #5

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