EFTA00022546.pdf
4.5 MB
Extraction Summary
9
People
6
Organizations
7
Locations
4
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal brief (reply brief)
File Size:
4.5 MB
Summary
This document is a Reply Brief filed by victims Jane Doe 1 and Jane Doe 2 in opposition to Jeffrey Epstein's intervention brief regarding remedies for violations of the Crime Victims' Rights Act (CVRA). The victims argue for the partial rescission of the Non-Prosecution Agreement (NPA) signed in 2007, specifically the immunity provisions, on the grounds that the agreement was illegally concealed from victims in violation of the CVRA. The brief refutes Epstein's arguments regarding due process, contract law, estoppel, and separation of powers, asserting that the NPA is unenforceable due to its illegal formation and the government's failure to confer with victims.
People (9)
| Name | Role | Context |
|---|---|---|
| Jane Doe 1 | Plaintiff/Victim |
Victim of Jeffrey Epstein seeking enforcement of rights under the CVRA.
|
| Jane Doe 2 | Plaintiff/Victim |
Victim of Jeffrey Epstein seeking enforcement of rights under the CVRA.
|
| Jeffrey Epstein | Intervenor/Respondent |
Convicted sex offender intervening to oppose the rescission of his Non-Prosecution Agreement.
|
| Bradley J. Edwards | Attorney |
Counsel for Jane Doe 1 and Jane Doe 2.
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| Paul G. Cassell | Attorney |
Counsel for Jane Doe 1 and Jane Doe 2 (Pro Hac Vice).
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| R. Alexander Acosta | Former US Attorney |
Former US Attorney for the Southern District of Florida who authorized the NPA.
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| Jeffrey Sloman | Former Assistant US Attorney |
Former First Assistant US Attorney quoted regarding the nature of the case.
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| Roy Eric Black | Attorney |
Counsel for Jeffrey Epstein.
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| Jacqueline Perczek | Attorney |
Counsel for Jeffrey Epstein.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| United States District Court, Southern District of Florida |
The court where the case is being heard.
|
|
| USAO-SDFL |
U.S. Attorney's Office for the Southern District of Florida (prosecutors who signed the NPA).
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| USAO-NDGA |
U.S. Attorney's Office for the Northern District of Georgia (representing the Government in this filing).
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| Edwards Pottinger LP |
Law firm representing the plaintiffs.
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| Black Srebnick Kornspan & Stumpf |
Law firm representing Jeffrey Epstein.
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| FBI |
Federal Bureau of Investigation.
|
Timeline (4 events)
2007-09-24
Execution of the Non-Prosecution Agreement (NPA).
Southern District of Florida
2019-07-23
Filing of Jane Doe 1 and 2's Reply to Intervenor Epstein's Brief.
US District Court, Southern District of Florida
Locations (7)
| Location | Context |
|---|---|
|
Jurisdiction where the NPA was signed and the CVRA violation occurred.
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Jurisdiction where Epstein was facing new sex trafficking charges in 2019.
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Location of one of Epstein's properties.
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Location of one of Epstein's properties.
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Location of one of Epstein's properties.
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Location of one of Epstein's properties.
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Location relevant to Epstein's sex offender registration.
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Relationships (2)
Worked together assiduously to hide the ball from the victims; conspired together to achieve non-conferral.
Jane Doe 1 is a crime victim covered by the CVRA; victim of a federal crime committed by Epstein.
Key Quotes (5)
"The Government decided 'to conceal the existence of the NPA and mislead the victims to believe that federal prosecution was still a possibility.'"Source
EFTA00022546.pdf
Quote #1
"Epstein's counsel was aware that the Office was deliberately keeping the NPA secret from the victims and, indeed, had sought assurances to that effect."Source
EFTA00022546.pdf
Quote #2
"This case involves deception of dozens of Florida victims of an international sex trafficking organization."Source
EFTA00022546.pdf
Quote #3
"Rescission will vindicate Jane Doe 1 and 2's CVRA rights, by permitting them to confer with prosecutors in this district about obtaining federal prosecution here — against Epstein and all of his coconspirators."Source
EFTA00022546.pdf
Quote #4
"The NPA's immunity provisions were founded in illegality — specifically, their concealment from the victims - something that Epstein well knew and, indeed, specifically sought."Source
EFTA00022546.pdf
Quote #5
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