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.
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.
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