EFTA00010542

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Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JANE DOE 1 AND JANE DOE 2, Civil Action No. PETITIONERS, V. UNITED STATES OF AMERICA, RESPONDENT. 08-80736-CIV-MARRA • Government's Response to Petitioners' Submission on Proposed Remedies The United States of America, by Byung J. Pak, United States Attorney for the Northern District of Georgia, and Jill E. Steinberg and Nathan P. Kitchens, Special Attorneys for the Southern District of Florida, files this response to Petitioners' proposed remedies. INTRODUCTION The question before this Court is what remedies, if any, should be accorded Petitioners under the Crime Victims Rights Act (CVRA) based on this Court's finding that the government failed to confer with Petitioners prior to entering into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 1 This Court previously found that Petitioners are crime victims under the CVRA; a crime victim's rights under the CVRA attach before the government brings formal charges against a defendant; the CVRA's "reasonable right to confer" extends to conferring about non-prosecution agreements; the CVRA authorizes the rescission of a non-prosecution agreement reached in violation of a prosecutor's conferral obligations; and the government violated the CVRA by failing to advise the victims that it intended to enter into the NPA w