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 Epstein. Based on this correspondence and other evidence, it is now clear that the U.S. Attorney's Office has repeatedly violated the protected rights of the victims under the CVRA, including their right to confer with prosecutors generally about the case and specifically about a non-prosecution agreement it signed with the defendant. It is now beyond dispute that in September 2007, the U.S. Attorney's Office reached a non-prosecution agreement with Jeffrey Epstein that barred his prosecution for numerous 1 EFTA00206764