Jane Doe H 1 and Jane Doe ft 2

Jane Doe H 1 and Jane Doe ft 2 United States Plaintiffs' Request for Production No. 7: Plaintiffs seek correspondence and documents regarding the government's knowledge of any obligations it had under the CVRA to notify the victims about the non-prosecution agreement and any related state court plea agreement. I understand there were discussions between the Child Exploitation and Obscenity Section (CEOS) and the S.D.Fla.. regarding whether the CVRA applied to the NPA, and whether notification should be made to the victims. This would include letters, memos, and e-mail traffic. No. 8: Plaintiffs seek documents relating to Epstein's efforts, after the execution of the NPA in September 2007, to appeal to Main Justice to obtain a more favorable outcome. I understand he first appealed to CEOS, which found the S.D.Fla. had acted within its discretion. Epstein's attorneys next sought review at the DAG level, which resulted in then Deputy Attorney General Mark Filip finding that t