DS9 Document EFTA00433383

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffre

Case 9:08-cv-80736-KAM Document 74

Case 9:08-cv-80736-KAM Document 74 Entered on FLSD Docket 05/02/2011 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO THEIR MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND TO HAVE THEIR UNREDACTED PLEADINGS UNSEALED COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, reply to the Government's response (DE #60) to their motion to use correspondence to prove violations of the Crime Victims' Right Act and to Have Their Unredacted Pleadings Unsealed (DE #51). The Government does not contest the first part of the victims' motion — that they should be allowed to use the correspondence to prove CVRA violations — and that part of the victims' motion should therefore be granted. The Government does argue that some parts

NAME SEARCHED: Jeffrey Epstein

DOJ EFTA Data Set 10 document EFTA01296720

09/18/2007 02:53

09/18/2007 02:53 PM To 'Jay Lefkowite < cc bec Subject Factual proffer Hi Jay — I didn't want us to get sidetracked during the conference call. I want to make sure that we have a factual basis for "harassment" Forcibly flying omewhere else is a different 1512 offense with a 10 year cap. 1 is is the factual proffer that I drafted up earlier this afternoon, to give you an idea of what it would look like. When I include a factual proffer in a plea agreement, I usually use prefatory language like: The parties agree that, had this case proceeded to trial, the United States would have proven the following facts beyond a reasonable doubt, and that the following facts are true and correct and are sufficient to support a plea of guilty . <Cpstein Plea Proffer.doc>> Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax «< Attachment 'Epstein Plea Proffer.doc' has been archived by user 'CommonStorellT/Klrkland•Ellls' on '11/26/2007

From: Lesley Groff <MINIII

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffrey