UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 UNITED STATES PARTIES JOINT STATEMENT OF UNDISPUTED FACTS AND PROPOSED SCHEDULE FOR RESOLUTION OF VICTIMS' PETITION COME NOW the parties in this action, Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and the United States, by and through undersigned counsel, to propose to the Court a joint stipulation of undisputed facts and a proposed schedule for final resolution of the victims' petition. As the Court is aware, the parties have been collecting evidence and negotiating over a joint proposed statement of undisputed facts in this case for some time now. Part of the reason for the time involved is that the parties have differing views on various aspects of this case. The parties, however, have recently jointly reached the conclusion that it is possible for them to agree on certain facts and to propose a schedule for this Court to bring the victims petition to final resolution if the Court will resolve one important legal issue. The parties jointly propose that the Court accept their stipulated facts, outlined below, and then direct briefing on the legal issue of whether the Crime Victims Rights Act (CVRA) applies on the facts of this case. The victims will argue that, because they were receiving CVRA notices and because the United States ultimately resolved the criminal case against Jeffrey Epstein with a formal non-prosecution agreement, the CVRA applied. The United States will respond that, because no indictment was ever filed in the case, the CVRA did not apply. The EFTA00207822