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EFTA00584357

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And I've tried to review as many of the pleadings as possible. As you know, they're extremely voluminous. And I haven't been through all of them. But we do believe that there has been a breach in the filing that Mr. Josefsberg referred to, and contrary to Mr. Critton, we do understand that we have an obligation to provide notice, and we are providing notice to Mr. Epstein today. The pleading that we found to be in breach -- the non-prosecution agreement, sought to do one thing, which was to place the victims in the same position they would have been if Mr. Epstein had been convicted of the federal offenses for which he was investigated. And that if he had been federally prosecuted and convicted, the victims would have been entitled to restitution, regardless of how long ago the crimes were committed, regardless of how old they were at the time, and how old they are today, or at the time of the conviction. And it also would have made them eligible for damages under 2255. And so our idea was, our hope was that we could set up a system that would allow these victims to get that restitution without having to go through what civil litigation will expose them to. that, of course, he would be entitled to depositions; of You have a number of girls who were very hesitant about even speaking to authorities about this because of the trauma that they have suffered and about the embarrassment that they were afraid would be brought upon themselves and upon their families. So we did through the non-prosecution agreement tried to protect their rights while also protecting their privacy. So, pursuant to the non-prosecution agreement -- on the other hand, we weren't trying to hand them a jackpot or a key to a It was solely to sort of put them in that same position. So we developed this language that said if -- that provided for an attorney to represent them. Most of the victims, as you know from the pleadings, come from not wealthy circumstanc

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